EU REACH Compliance for Sellers

ECHA maintains the SVHC candidate list. Concentration thresholds, SCIP timing and Annex XVII limits: confirm on ECHA / EUR-Lex. This page does not freeze 0.1% or a substance count.

Common violations: Cadmium in cheap jewellery and metal accessories (limit: 0.01% w/w); Lead in solder joints of electronics, painted surfaces and ceramic glazes (limit: 0.05% w/w for consumer articles); DEHP/DBP/BBP/DIBP (four phthalates) in PVC components, cables, soft toys (limit: 0.1% w/w each); Nickel release from metal buttons, zippers and jewellery in skin contact (limit: 0.5µg/cm²/week); PAHs (polycyclic aromatic hydrocarbons) in rubber tyres, plastic handles, sports equipment (limit: 1mg/kg for consumer articles); PFAS in water-resistant textiles and cookware coatings. Testing at an accredited lab (SGS, Intertek, TÜV) costs ask the operator for the current rate depending on the number of substances screened.

REACH registration is required for any company importing a chemical substance (including substances in mixtures) into the EU in quantities of 1 tonne or more per year. For most cross-border sellers of finished articles (electronics, clothing, toys, household goods), registration is NOT required because substances in articles are only subject to registration if they are intended to be released (e.g., scented products, ink refills) and the total quantity exceeds 1 tonne/year. However, the SVHC notification and information obligations still apply to articles regardless of tonnage. If you import raw materials or chemical formulations (paints, adhesives, cleaning products) into the EU, you likely need to register with ECHA.

The SCIP (Substances of Concern In Products) database is maintained by ECHA under the Waste Framework Directive. If you supply an article containing an SVHC above 0.1% w/w into the EU, you must submit a SCIP notification before the product can be sold. The notification must include: the article's identification (name, product category, material), the SVHC name and concentration range, and safe use information. The notification is free and submitted through ECHA's online portal. You receive a SCIP notification number that should be referenced in your product documentation. Retailers and marketplaces increasingly request the SCIP number as proof of compliance. The obligation applies to every distinct article — if you sell the same product in different colours or sizes, each variant may need a separate notification if the SVHC content differs.

REACH and RoHS (Restriction of Hazardous Substances Directive 2011/65/EU) are separate regulations with overlapping but distinct scopes. RoHS applies specifically to electrical and electronic equipment and restricts 10 substances (lead, mercury, cadmium, hexavalent chromium, PBB, PBDE, and four phthalates) with specific maximum concentration values (e.g., cadmium 0.01%, others 0.1% by weight in homogeneous materials). REACH has broader scope — it covers all products and 240+ SVHCs. A product can be RoHS-compliant but still contain SVHCs above the 0.1% REACH threshold (for example, a RoHS-compliant electronic device may still contain DEHP above 0.1% in a non-homogeneous component). You must comply with both: RoHS for the electronics-specific restrictions, and REACH for SVHC notification and any additional Annex XVII restrictions. Testing labs typically offer combined REACH + RoHS test packages at a discounted rate compared to ordering separately.