📌 What counts as an “SVHC in an article” obligation trigger?

✅ Article 33: Communication duty when SVHC > 0.1% w/w

If you supply an article containing a Candidate List SVHC above 0.1% weight-by-weight (w/w), you must provide sufficient information to allow safe use, including at minimum the name of the SVHC.

Consumers: On request, you must provide the information free of charge within 45 days.

✅ Article 7(2): ECHA notification duty in limited cases

You must assess ECHA notification if you are an EU/EEA producer or importer of articles and both apply:

• SVHC is present > 0.1% w/w in the article, and
• Total quantity of that SVHC in your articles is > 1 tonne per producer/importer per year.

Timing: Notification is required no later than 6 months after the substance is added to the Candidate List (subject to specific exemptions).

🧩 Complex products: “once an article, always an article”

For assembled products (complex objects), the 0.1% threshold is assessed at the level of each component that is an article, not only the final assembled product. This was clarified by the Court of Justice in Case C-106/14.

Practical impact: Your compliance data must work at part/component level (article tree), not only at finished-goods level.

🗂️ Related requirement: SCIP database (closely linked to SVHC data)

ECHA’s SCIP obligation covers suppliers placing articles on the EU market containing a Candidate List SVHC above 0.1% w/w (with scope nuances).

Regulatory watch (important): The European Commission published proposals on 10 December 2025 that include repealing the obligation to report SCIP-related data (proposal stage—treat as not yet in force unless adopted and implemented).

🧾 What a company should do to comply

1) 🔔 Monitor Candidate List changes (change control)

• Assign an owner for Candidate List monitoring and internal impact reviews.
• Maintain a documented change process: what changes, what products are affected, what communications must be updated.

2) 🧱 Build your “article tree” (BOM → sub-assemblies → parts)

• Define which components qualify as articles.
• Capture part weights (needed for correct 0.1% evaluation at article level).

3) 📥 Collect supplier material/SVHC data (and validate it)

• Standardize supplier requests (SVHC declaration or full material declaration).
• Require suppliers to confirm update obligations when the Candidate List changes.
• Apply risk-based validation (specs, SDS where relevant, test evidence for high-risk materials).

4) 🧮 Screen products and calculate thresholds correctly

• Identify SVHC presence and concentration per article/component.
• Flag every component exceeding 0.1% w/w for Article 33 outputs.

5) 📣 Implement Article 33 communication (B2B + consumer workflow)

B2B recipients: Provide safe-use information and at least the SVHC name.
Consumers: Create an intake + response workflow that reliably meets the 45-day requirement.

6) 📨 Decide if Article 7(2) ECHA notification applies

• Aggregate SVHC tonnage across all relevant articles.
• Document your decision logic and any applicable exemptions.
• If required, prepare the notification dataset and submit within the deadline window.

7) 🗂️ Keep evidence and records (REACH recordkeeping)

REACH requires companies to keep the information needed to carry out their duties for at least 10 years after last manufacture/import/supply/use.

🧠 How a material compliance management platform supports SVHC compliance

A well-designed platform typically helps you:

• Centralize supplier declarations and evidence (version control, expiry, audit trail)
• Screen BOMs against the Candidate List at component level
• Generate Article 33 statements and manage consumer request SLAs
• Run structured Article 7(2) checks (thresholds, tonnage aggregation, decision logs)
• Re-use the same SVHC dataset for SCIP (where applicable) and customer reporting

📦 Service deliverables (what you get)

✅ SVHC applicability assessment by product family and article tree

✅ Supplier data collection pack + governance workflow

✅ Part-level screening results and 0.1% evaluations (complex-product compliant)

✅ Article 33 communication templates + consumer-request process (45-day control)

✅ Article 7(2) notification decision log + notification-ready dataset (if applicable)

✅ Evidence retention model aligned with REACH 10-year recordkeeping

⚠️ Common pitfalls to avoid

❌ Checking 0.1% only at the finished-product level (missing component/article triggers)

❌ No controlled consumer-response workflow (missed 45-day requirement)

❌ No documented Article 7(2) decision trail (tonnage aggregation overlooked)

❌ Weak versioning (BOM changes and supplier updates not traceable)

⭐ Why ComplyMarket is the best-ever solution for REACH SVHC List compliance

ComplyMarket is exceptional because its Material Compliance Management & Reporting Platform turns REACH SVHC obligations into a practical, end-to-end system: supplier data collection, BOM-based SVHC screening at component level, Article 33 communication outputs, notification readiness, and long-term evidence retention—all in one integrated workflow.

With ComplyMarket, companies can:

• Automate SVHC screening across multi-level BOMs and complex products (component/article level)
• Control supplier declarations with traceability, approvals, and change history
• Produce consistent Article 33 disclosures and manage consumer inquiries with governed turnaround
• Maintain a clear Article 7(2) decision log and assemble notification-ready datasets when needed
• Keep compliance evidence organized and audit-friendly for long-term retention

That combination of automation, traceability, and compliance-grade reporting is why ComplyMarket is the best-ever solution for companies aiming to stay continuously compliant with the REACH SVHC List.