REACH SVHC Updates: What a Candidate List Revision Means for Your BOM
ECHA updates the SVHC Candidate List roughly twice a year. Each update is a fresh scope question for every product you sell into the EU.
The REACH Candidate List of Substances of Very High Concern doesn't grow on a schedule you control. ECHA typically adds new entries once or twice a year, and each addition takes effect immediately — there's no grace period before the notification and communication obligations apply.
That immediacy is the part teams underestimate. The moment a substance is added, any article you place on the EU market containing it above 0.1% by weight, in any homogeneous part, triggers two separate obligations: telling your customers (and on request, consumers, within 45 days), and — if the article is sold as a separate article rather than incorporated into a larger one — a SCIP database notification to ECHA.
Why this is a supply chain problem, not a legal one
Legal teams can track the Candidate List. What they usually can't do alone is answer the question that actually matters: does this substance appear anywhere in our current bill of materials?
That answer depends on:
- Whether your suppliers know their own formulations well enough to say yes or no with confidence
- Whether "no" means "verified absent" or "nobody checked"
- Whether the part in question is even mapped to a specific homogeneous material, or just a general "compliant" claim
A Candidate List update is only actionable if you can run it against real material-level data. Otherwise it's a legal notice with nowhere to land.
A practical response pattern
- Screen immediately, not at the next audit cycle. Cross-reference the new entries against your live substance database the day they're published.
- Push targeted requests, not blanket re-declarations. Ask only the suppliers whose material category could plausibly contain the new substance — this gets faster, higher-quality responses than a mass email.
- Log the negative results too. "Confirmed absent as of [date]" is defensible evidence. Silence is not.
- Re-run SCIP notifications where required, and don't assume last year's dossier still applies if the underlying substance composition has changed.
REACH doesn't reward the fastest legal read of the Candidate List. It rewards whoever can turn that list into a supplier question the same afternoon it's published.