EU REACH SVHC 224: Compliance Guide for Importers

Oct 26, 2026

Practical SVHC candidate list (224 entries as referenced) workflow for importers: threshold and communication duties, documentation chain, screening steps and the gaps that most often cause problems.

EU REACH SVHC 224: Compliance Guide for Importers

What does the SVHC candidate list actually oblige an importer to do? Three duties matter most: know whether any candidate list substance is present above 0.1% by weight in your article, communicate that information through the supply chain and to consumers on request, and, for suppliers placing articles on the EU market, consider the SCIP notification duty. This guide sets out the practical workflow; it is general information, not legal advice, and the current list version should always be verified with the official source.

What the candidate list is

The candidate list is published under the European chemicals regulation and grows over time as substances are added. The version referenced in our documentation contains 224 entries. Because the list is updated periodically, the first step of any compliance programme is to confirm which version you are working to and the date it applies from.

ConceptWhat it means in practiceWho acts
Candidate listSubstances identified as of very high concernImporters and suppliers check their articles
0.1% w/w thresholdThe concentration above which communication duties apply in an articleThe party placing the article on the market
Article 33 communicationPassing information down the supply chain and to consumers on requestThe article supplier
SCIP notificationNotification of articles containing candidate list substancesSuppliers placing articles on the EU market
Documentation chainTechnical data, safety data and batch reportsManufacturer to importer to end user

The importer workflow

A workable programme follows the material rather than the paperwork. Start from the bill of materials, map each component to its supplier declaration, and only then decide whether testing is needed.

StepActionEvidence to keep
1Map the bill of materials and identify chemical componentsBill of materials and supplier list
2Collect declarations, TDS, MSDS and batch COASigned declarations per component
3Screen against the current candidate list versionScreening record with the list version
4Test where a declaration is missing or doubtfulTest report from an accredited laboratory
5Prepare communication and, where applicable, notificationArticle 33 text and SCIP dossier
6Re-run the screening when the list is updatedUpdate log and revision history

For plasticizer selection, the practical point is that non-phthalate grades in the DB series are screened against the REACH SVHC 224-item direction, with DINCH (CAS 166412-78-8), TOTM (CAS 3319-31-1) and the fumarate and phosphate grades documented individually. Proprietary formulations are declared as such rather than assigned a public registry number.

Where importers most often go wrong

Common gapWhy it happensHow to close it
Screening against an outdated list versionThe list grows over timeRecord and date the version used
Declarations without batch evidenceCollected once at the start of a projectRequest batch COA with each delivery
Confusing mixture and article dutiesDifferent provisions applyClassify the product before deciding
Missing notification stepFocused only on documentationReview the notification duty separately
No re-screening processOne-off project approachBuild list updates into change control

Frequently asked questions

Is 0.1% measured on the article or the component? The threshold applies to the article as placed on the market, which is why component data has to be converted into an article-level statement.

Does a TDS replace a compliance declaration? No. A technical data sheet describes performance; the declaration states the compliance position for a specific list version and should be dated.

What should a declaration contain? The substance list version, whether any candidate list substance is present above the threshold, and the identity of the party issuing the statement.

Where can the current list be confirmed? From the official source maintained by the European Chemicals Agency; always work to the current version and record it.

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Our team can provide the current technical data, safety data and compliance statements for the grades you are evaluating, together with a 1kg complimentary testing sample dispatched worldwide via DHL or FedEx. Trial order MOQ is 1 MT, and bulk shipments are loaded as 23 MT flexitank containers from Ningbo or Shanghai.

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