EU REACH SVHC Compliance Checklist (Free)

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10 critical items still open - these are the highest-risk gaps.

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Role and scope

Determined your role for each product: manufacturer, importer, downstream user, distributor or article producerCRITICALListed EU legal entities and any non-EU suppliers that may appoint an only representativeSeparated substances, mixtures and articles in the product portfolioIdentified products placed on the EU or EEA market and their intended marketsNamed a REACH compliance owner and a deputy

Candidate List screening

Subscribed to ECHA updates so each Candidate List revision is received promptlyCRITICALScreen the full bill of materials against the current Candidate List after each updateCRITICALScreening is performed at article level, using the concentration in the article, not only the finished productApplied the 0.1 percent weight-by-weight threshold correctly to each article within a complex productCRITICALRecorded the result per part number, substance, CAS or EC number, concentration and dateChecked Annex XIV (authorisation) and Annex XVII (restriction) as well as the Candidate ListReviewed packaging, spares, accessories and consumables, not just the main product

Supplier data

Sent a REACH declaration request to every relevant supplier at each Candidate List updateCRITICALRequested the substance name, concentration range and safe use information when an SVHC is presentCRITICALFollowed up non-responders with escalation and recorded the outcomeIncluded REACH clauses in purchase terms and supplier quality agreementsUsed a standard format for supplier data, such as IPC-1752 style declarations or a tool of your choiceStored supplier declarations against the part number with an expiry or review date

Communication and notification

Prepared Article 33 information to give to professional recipients when an article contains an SVHC above 0.1 percentCRITICALSet a process to answer consumer requests within 45 daysCRITICALChecked SCIP database notification duties for articles containing Candidate List substances above 0.1 percentCRITICALAssessed whether notification to ECHA is needed for SVHC in articles above 1 tonne per producer or importer per yearSafe use information includes at least the substance name, to allow safe handlingCustomer communications are consistent across datasheets, portals and the safety data sheet where relevant

Management and change

Substitution options were considered for SVHC found in productsEngineering change control checks new parts and suppliers for REACH status before releaseCRITICALRecords are retained and can be produced to authorities on requestStaff in purchasing, engineering and quality received REACH trainingAudit or review of the process is scheduled at least annually

REACH obligations depend on your role (manufacturer, importer, downstream user, or producer of articles) and on tonnage. Confirm your role and the current lists with ECHA and your legal adviser.

Screen your BOM against supplier declarations

We can outline a private workflow that matches part numbers with declarations stored in your ERP and file shares. Optional.

Optional. The tool and every export work without this. No spam.

How to use this checklist

Start with your role and scope, then work through screening, supplier data, communication and change control. Tick only the items you can evidence with a document or a system record. Export the result and use the gaps as the agenda for your next compliance review. Run the checklist again whenever ECHA updates the Candidate List, since new substances can instantly change the status of existing products without any design change on your side.

The rules behind the checklist

Under REACH, the Candidate List identifies substances of very high concern. If an article contains such a substance above 0.1 percent weight by weight, the supplier must give recipients enough information to allow safe use, at least the substance name (Article 33). Consumers can request it, and the supplier must reply within 45 days. Suppliers of articles must also submit information to the SCIP database under the Waste Framework Directive. Producers and importers may have a separate notification duty to ECHA above one tonne a year.

0.1 percent applies to each article, not the whole product
Article 33 covers professional recipients and consumers on request
SCIP notification is a separate duty from Article 33
The Candidate List is updated a couple of times per year

Worked example

A control panel contains a connector housing, a cable and a PCB. A new Candidate List update adds a substance used in a cable sheath at 0.3 percent of that cable. The cable is an article within the product, so the 0.1 percent test applies to the cable, and the panel maker must inform customers and file a SCIP notification. If the same substance were found at 0.05 percent, no communication would be triggered, but the record should be kept.

Common mistakes

Frequent errors include calculating the threshold on the finished product, relying on out-of-date supplier declarations, forgetting spares and packaging, and treating a RoHS declaration as proof of REACH status. They are different laws with different substance lists. In the ERP, keep a REACH status attribute on the part or item revision so a new supplier part cannot be released without a declaration.

Frequently Asked Questions

What does 0.1 percent apply to?

The 0.1 percent weight-by-weight threshold applies to each article incorporated in a complex product, following the court ruling often referred to as once an article, always an article. It is not calculated across the whole finished product.

Is REACH the same as RoHS?

No. RoHS restricts a short list of substances in electrical and electronic equipment. REACH covers a much wider range of substances and has communication, notification and authorisation duties. Compliance with one does not prove compliance with the other.

What is the SCIP database?

SCIP is an ECHA database of information on articles containing Candidate List substances above 0.1 percent. Suppliers of such articles in the EU submit information so that waste operators and consumers can access it later.

How often should we screen?

Each time ECHA updates the Candidate List, and whenever a part, supplier or material changes. Many manufacturers also run an annual full review of supplier declarations to catch expired or inconsistent data.

If you want to cross-check your bill of materials against supplier declarations held in your ERP and document stores, Netray can help build that review on infrastructure you control.

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