How to Track the SVHC Candidate List: A Practical Guide for Manufacturers
The SVHC (Substance of Very High Concern) Candidate List is the core reference point under REACH for deciding when your product triggers supply chain communication or a direct notification duty. The list is updated on a rolling basis, the threshold calculation usually works differently than assumed, and two separate obligations, Article 33 and Article 7(2), get confused often. This guide gives manufacturers and exporters a practical framework for tracking it correctly.
What Is the SVHC Candidate List, and How Often Is It Updated?
SVHCs are substances that meet the criteria set out in Article 57 of the REACH Regulation: carcinogenicity, mutagenicity, reproductive toxicity, persistent-bioaccumulative-toxic properties, or an equivalent level of concern. ECHA collects substances that meet these criteria on an official register known as the Candidate List; once a substance is added, supply chain communication duties, and in some cases a direct notification duty, begin.
The list isn't updated on a fixed calendar. It grows whenever ECHA and Member States complete the evaluation process for a proposed substance. That means tracking it with a once-a-year check is risky. The four most recent updates below show it happening several times a year, without advance notice.
| Update Date | Substances Added | New Total |
|---|---|---|
| 21 January 2025 | 5 | 247 |
| 25 June 2025 | 3 | 250 |
| 5 November 2025 | 1 | 251 |
| 4 February 2026 | 2 | 253 |
Last checked: September 2026. Source: ECHA Candidate List announcements. For the current, complete list, always checkECHA's official Candidate List table.
Article 33 (Supply Chain Communication) vs. Article 7(2) (Importer Notification)
REACH Article 33 applies any time a Candidate List substance in your article exceeds 0.1% by weight, with no tonnage threshold at all. It creates two separate duties: automatically informing the commercial recipient you supply the article to, and providing information to a consumer who asks, free of charge, within 45 days.
Article 7(2) is a narrower duty: only if an SVHC in your articles both exceeds 0.1% by weight and the total quantity of that substance across all such articles you produce or import exceeds 1 tonne per year, are you required, as a producer or importer, to notify ECHA directly.
Which One Applies When?
A company producing low-volume, component-based products usually only falls under Article 33: the concentration threshold is met, but total tonnage stays low. Companies with high production volumes, or importing large quantities of the same part (a cable type, for example), can trigger both duties at once: informing the buyer and notifying ECHA. Before you settle on your obligations, both thresholds, concentration and tonnage, need to be checked separately.
Is the 0.1% Threshold Calculated per "Product" or per "Article"? A Common Mistake
The mistake we see most often is calculating the 0.1% threshold against the entire finished product. Under REACH, though, the threshold is calculated for each individual article, not the product as a whole. The Court of Justice of the European Union clarified this in its judgment of 10 September 2015, Case C-106/14: where a complex object is made up of more than one article, notification and communication duties are assessed for each component article that retains its own shape, surface, or design, not for the assembled product as a whole.
Take a cable assembly as an example: the metal connector, the plastic insulation, and the internal wire are each separate articles. An SVHC concentration in the connector is calculated against the connector's own weight, not the weight of the whole assembly. This distinction often flips the result: a substance that stays under the threshold when calculated against the whole product can easily exceed it once calculated correctly, per component.
The Risks of Tracking the List Manually, and Why We Use ECHA's Official Search Tool
Tracking the list by hand (downloading a PDF and pasting it into a spreadsheet) carries a few concrete risks: the list updates multiple times a year without advance notice; a small typo in a CAS or EC number can make you miss a substance entirely; and if your supply chain has many components, screening each one manually is slow and goes stale quickly.
Rather than building our own SVHC database and claiming it's "current," we run scope assessments through ECHA's official Candidate List search tool, which means the currency of the list is guaranteed by the regulator itself, not by us. When we screen your product's substance/component list systematically through this tool, we also apply the correct per-article threshold calculation described above.
How the Notification Clock Works When a New Substance Is Added
Obligations start on the date a substance is officially added to the Candidate List. There is no grace period for the Article 33 communication duty: from the moment the substance is added, if it exceeds 0.1% in your article, you need to inform your buyers. Article 7(2) is different: for articles already on the market when the substance is added, a six-month notification window applies; for articles you place on the market after that date, the notification must be completed before placing the product on the market, the six-month window does not apply there.
So the first thing to do when a substance is added is to work out which articles in your product portfolio contain it, and which of those are already on the market versus not yet placed on the market, since the clock runs differently for each group.
If you've identified an SVHC in your scope, or you're not sure about the threshold calculation, our REACH compliance processowns this assessment from scope to technical file, including the required analyses.