SVHC substances and importer obligations: the list rises to 253 entries

SATURDAY, 12 SEPTEMBER 2026

Since 4 February 2026 the REACH Candidate List contains 253 entries: above 0.1% by weight information duties and SCIP database notification are triggered.

SVHC substances and importer obligations are a subject that updates twice a year and that almost nobody rereads between one update and the next. Since 4 February 2026 the Candidate List under the REACH regulation contains 253 entries, and the deadline for notifying the European agency about articles containing the latest two substances has already passed.

SVHC substances and importer obligations: what the 0.1% triggers

The Candidate List gathers the substances of very high concern identified under the REACH regulation. It is not a ban: it is a list that triggers information duties along the supply chain.

The threshold is 0.1% by weight. If an article contains a listed substance above that concentration, the supplier must pass on to customers the information needed for safe use. On a consumer's request, the same information must be provided within 45 days.

There is then a second obligation, often overlooked because it comes from a different piece of law. Since 2021, under the waste framework directive, anyone placing on the European market articles above that threshold must notify them to the SCIP database of the European chemicals agency. The notification must be made within six months of the substance being added to the list.

The figures of the Candidate List

• Entries in the Candidate List after the update: 253
• Substances added on 4 February 2026: 2, n-hexane and BPAF with its salts
• Concentration threshold that triggers the duties: 0.1% by weight
• Time to answer a consumer's information request: 45 days
• Deadline to notify the SCIP database from inclusion in the list: 6 months

The arithmetic is quick: for the two substances added in February, the six months expired on 4 August 2026. Anyone importing articles that contain them above the threshold and has not notified is already out of time, and in all likelihood does not know it, because nobody told them.

The signal coming from Asian suppliers

That the subject is becoming commercial, and not merely regulatory, is visible in who is building a service on it. Oki Engineering, a subsidiary of the Japanese group Oki Electric Industry, launched on 4 September an analysis service to identify the chemical substances present in products destined for export to Europe, with testing carried out in Japan and pricing set by quotation. The company is targeting 100 million yen of revenue, around 548 thousand euro, by the end of the 2027 financial year.

The interesting figure is not the expected revenue, it is the direction. An Asian supplier opening a laboratory to certify REACH compliance does so because European buyers have started asking for it as a condition, not as a courtesy. Those who do not ask now stand out for the wrong reason.

What to do before the goods leave

Checking composition is one of those activities that cost little before shipment and a great deal afterwards. A container held at customs over a documentary challenge generates demurrage that accrues daily, and the substance cannot be removed from the product once it has arrived.

Three concrete steps, in order of usefulness. The first is to ask the supplier for a composition declaration that explicitly cites the Candidate List and its current version: a generic declaration of conformity is not enough, because the list changes and a statement referring to an old version does not cover entries added later.

The second is to have the highest-risk product codes analysed at least once, typically those containing plastics, rubbers, paints, surface treatments and electronic components. There is no need to test the whole catalogue: what is needed is knowing which product families are exposed.

The third is to put the clause in the supply contract, not in the correspondence. If the duty to disclose listed substances and to update the declaration at every revision of the Candidate List is written into the order, responsibility is defined before anyone needs to argue about it.

With La Merce, handling SVHC substances and importer obligations means asking the supplier for the composition declaration referring to the list updated to 253 entries before the goods leave, and having the highest-risk codes analysed when that declaration is not enough to settle the point.

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