REACH — Regulation (EC) No 1907/2006 — is the EU's chemicals regulation, and SVHC is the part of it that reaches deepest into the plastics supply chain: substances of very high concern. A reach svhc plastic declaration is the document an EU buyer asks a supplier for, stating whether any substance on the REACH Candidate List is present in the article, at what concentration, and above which threshold. It is not a certificate, it is not a test report, and for most supply relationships it is not optional — Article 33 of REACH places a duty on suppliers to communicate SVHC content down the chain. This guide explains what the Candidate List is, what a defensible declaration contains, and what EU buyers should require from a plastics supplier.
What SVHC Means and Why Plastics Are Affected
SVHC is a regulatory status, not a chemical family. A substance lands on the Candidate List if it meets the criteria for being carcinogenic, mutagenic or toxic to reproduction (CMR), persistent, bioaccumulative and toxic (PBT), very persistent and very bioaccumulative (vPvB), or of equivalent concern such as endocrine-disrupting properties. The list is maintained by ECHA and updated roughly twice a year; it has grown past two hundred entries. Plastics meet the list through additives and residues more often than through the polymer itself: certain phthalate plasticisers such as DEHP, DBP, BBP and DIBP, some brominated flame retardants, lead-based heat stabilisers, and specific colorants and UV absorbers. A plastic part can be perfectly lawful to sell and still require a declaration — that is the part buyers most often misunderstand.
The 0.1% Threshold and Article 33
The trigger is concentration: if an SVHC is present in an article at more than 0.1% weight by weight, the supplier must give recipients and consumers enough information to allow safe use, including at minimum the substance name. Below that threshold, no Article 33 notification is triggered for the article. Two details matter in practice. First, the threshold applies per article, not per shipment — a connector housing, a label and a cable are separate articles. Second, the duty includes answering consumer requests without charge within 45 days, which is why branded retail supply chains push declarations upstream to the moulder. An article 33 declaration is therefore the standard artefact: a statement keyed to a part number, listing SVHC content above the threshold with CAS numbers and concentration ranges.
What a Defensible REACH SVHC Plastic Declaration Contains
A useful svhc declaration is specific enough to audit:
- Part identification — part number and revision, so the declaration is tied to a configuration, not a product family.
- Substance list — each Candidate List substance present above 0.1% w/w, with CAS and EC numbers and the concentration or range.
- Candidate List version — the date of the list version the assessment was run against, because the list changes and an old declaration silently expires.
- Basis of assessment — full material declarations from the supply chain, or test data, or a reasoned engineering judgement; the basis should be stated.
- Date and signatory — a dated commitment from a named responsible function at the supplier.
The most common defect is a generic certificate: a document that lists half the Candidate List, declares everything "below threshold", and is not tied to any part number. Such a document cannot be audited and does not satisfy the information duty in substance. The second most common defect is a declaration checked against a list version from years ago, which misses every substance added since. The reach candidate list is a moving target, and a declaration is only as current as the version it cites.
SCIP and the Waste Framework Directive
Since January 2021, suppliers placing articles containing Candidate List substances above 0.1% w/w on the EU market must also submit information to ECHA's SCIP database under the Waste Framework Directive. The obligation sits with EU-based suppliers and importers, but non-EU producers feed them the data. For buyers, SCIP is a useful cross-check: a part whose declaration claims no SVHC but appears in a supplier's SCIP submission is a contradiction worth a conversation. It is also a reason to ask, inside the declaration itself, whether the data has been reported to SCIP.
What EU Buyers Should Require
Treat the declaration as a living document tied to the part number. Require an update whenever a new Candidate List version is published — roughly every six months — rather than a one-off statement at program start. For high-risk items, ask for test evidence on the specific substance of concern rather than a declaration alone; a declaration is a statement, a test report is evidence, and the two answer different questions. Check that the declaration version matches the current list, that the part number matches the purchase order, and that the signatory is identified. Finally, keep the declarations with the technical file: the duty to supply information can arise years after the parts shipped, and the paper trail is what answers it.
REACH sits inside a wider compliance picture that also includes RoHS, food-contact rules and packaging legislation — the EU and US plastics compliance map puts the regimes side by side, the RoHS and REACH guide for modified PPS shows how a material-specific declaration reads in practice, and the EU food contact regulation guide covers the overlapping food-contact duties. Verified suppliers can be shortlisted through the China plastics company directory.
Related product categories
The materials and part types discussed above are grouped in our sourcing directory:
