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.
| Concept | What it means in practice | Who acts |
|---|---|---|
| Candidate list | Substances identified as of very high concern | Importers and suppliers check their articles |
| 0.1% w/w threshold | The concentration above which communication duties apply in an article | The party placing the article on the market |
| Article 33 communication | Passing information down the supply chain and to consumers on request | The article supplier |
| SCIP notification | Notification of articles containing candidate list substances | Suppliers placing articles on the EU market |
| Documentation chain | Technical data, safety data and batch reports | Manufacturer 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.
| Step | Action | Evidence to keep |
|---|---|---|
| 1 | Map the bill of materials and identify chemical components | Bill of materials and supplier list |
| 2 | Collect declarations, TDS, MSDS and batch COA | Signed declarations per component |
| 3 | Screen against the current candidate list version | Screening record with the list version |
| 4 | Test where a declaration is missing or doubtful | Test report from an accredited laboratory |
| 5 | Prepare communication and, where applicable, notification | Article 33 text and SCIP dossier |
| 6 | Re-run the screening when the list is updated | Update 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 gap | Why it happens | How to close it |
|---|---|---|
| Screening against an outdated list version | The list grows over time | Record and date the version used |
| Declarations without batch evidence | Collected once at the start of a project | Request batch COA with each delivery |
| Confusing mixture and article duties | Different provisions apply | Classify the product before deciding |
| Missing notification step | Focused only on documentation | Review the notification duty separately |
| No re-screening process | One-off project approach | Build 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.
Request documentation and a sample
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.
Sample and ordering
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