# REACH SVHC supplier declaration: Article 33 guide for importers

> REACH for importers of articles: SVHC communication under Article 33, ECHA notification and SCIP, and Annex XVII restrictions such as PFHxA and formaldehyde.

Source: https://sourcesquid.co/compliance/reach/

EU · Chemicals · Regulation (EC) No 1907/2006

# REACH: know what is in every material.

Under REACH (Regulation (EC) No 1907/2006), any supplier of an article containing a Candidate List substance of very high concern (SVHC) above 0.1% weight by weight must give its customers enough information for safe use, at minimum the substance name (Article 33). Separately, Annex XVII restrictions set hard limits for specific substances, such as PFHxA from 10 October 2026 and formaldehyde release since 6 August 2026.

[Get my REACH risk matrix](https://sourcesquid.co/start/?from=compliance-reach) See the key dates

0.1% w/w
    SVHC threshold, per article

45 days
    to answer a consumer request

6 months
    to notify ECHA after listing

Status · checked 28 Sep 2026 **PFHxA limits from 10 Oct 2026**

  1. 5 Jan 2021SCIP notifications begin
  2. 6 Aug 2026Formaldehyde release limits for articles
  3. Today28 Sep 2026
  4. 10 Oct 2026PFHxA restriction, first phase
  5. 10 Oct 2027PFHxA restriction, second phase

All dates and references ↓

The short answer

## What you need to know.

Checked against official sources on 28 September 2026.

  1. 01

REACH has two tools that matter most to importers of finished goods: the **Candidate List** of SVHCs, which triggers information duties, and **Annex XVII** , which restricts specific substances outright.

  2. 02

**Article 33:** if an article contains a Candidate List SVHC above **0.1% w/w** , tell your business customers, and consumers on request within **45 days** , enough for safe use, at least the substance name. The threshold applies to each article in a complex product (CJEU, C-106/14).

  3. 03

**Article 7(2):** importers notify ECHA when an SVHC is above 0.1% and above **one tonne per year** across their articles, within **six months** of it joining the Candidate List. Since 5 January 2021 article suppliers also submit Article 33 information to ECHA’s **SCIP** database.

  4. 04

ECHA adds substances to the Candidate List over time, and each addition can create duties straight away. Supplier declarations should name the **list version** they were checked against.

  5. 05

**Annex XVII** dates to plan for: formaldehyde release limits for articles since **6 August 2026** ; **PFHxA** limits in consumer clothing, footwear, food-contact paper, consumer mixtures and cosmetics from **10 October 2026** , and in other consumer textiles from 10 October 2027.

Who it applies to

## Every supplier of articles passes information on.

Importer

### EU importers of articles

Article 33 communication, ECHA notification above one tonne a year, SCIP submissions and compliance with Annex XVII restrictions.

Distributor

### Wholesalers and retailers

Article 33 applies to any supplier of an article, so the SVHC information travels with the goods to the shelf.

Brand

### Consumer product brands

Answer consumer requests within 45 days and make sure restricted substances stay below Annex XVII limits.

Factory abroad

### Suppliers in India, China, Vietnam

Not bound by REACH directly, but the only ones who know what went into each material. Their declarations and test data make your compliance possible.

Key dates

## Every date, with its source.

Dates set in the REACH restriction regulations. Candidate List additions happen on ECHA’s own schedule; check the live list.

  1. 5 Jan 2021

### SCIP notifications begin

Suppliers of articles provide Article 33 information to ECHA under the Waste Framework Directive.

Dir. 2008/98/EC Art. 9(1)(i), as amended by Dir. (EU) 2018/851In force

  2. 6 Aug 2026

### Formaldehyde release limits for articles

No more than 0.062 mg/m³ for furniture and wood-based articles and 0.080 mg/m³ for other articles, under the Appendix 14 test conditions.

Annex XVII entry 77; Reg. (EU) 2023/1464In force

  3. Today · 28 September 2026
  4. 10 Oct 2026

### PFHxA restriction, first phase

PFHxA and its salts below 25 ppb, PFHxA-related substances below 1,000 ppb, in consumer clothing textiles, leather and accessories; consumer footwear; food-contact paper and board; consumer mixtures; cosmetics. Articles placed on the market before this date are exempt.

Annex XVII entry 79; Reg. (EU) 2024/2462Upcoming

  5. 6 Aug 2027

### Formaldehyde limit for vehicle interiors

0.062 mg/m³ in the interior of road vehicles.

Annex XVII entry 77Upcoming

  6. 10 Oct 2027

### PFHxA restriction, second phase

The same limits for consumer textiles, leather, furs and hides other than clothing and accessories, such as home textiles.

Reg. (EU) 2024/2462Upcoming

Three duties, one list

## What a Candidate List SVHC triggers.

For an SVHC above 0.1% weight by weight in an article you import into the EU.

Duty| Who| Trigger| Timing  
---|---|---|---  
Inform business customers (Art. 33(1))| Any supplier of the article| SVHC above 0.1% w/w| With the article, at least the substance name  
Answer consumers (Art. 33(2))| Any supplier of the article| A consumer request| Within 45 days, free of charge  
Notify ECHA (Art. 7(2))| Producer or importer of articles| SVHC above 0.1% and above 1 tonne per year| Within 6 months of listing  
SCIP database| Suppliers of articles| SVHC above 0.1% w/w| Since 5 January 2021  
  
The Article 7(2) notification is not needed where exposure to humans and the environment can be excluded during normal use and disposal (Art. 7(3)).

What you need from suppliers

## What to ask your factory and its suppliers.

Declarations are only as good as the material data behind them. We collect both.

  * **SVHC declaration per article** Signed, naming the Candidate List version checked, and stating any SVHC above 0.1% w/w per component.
  * **Bill of materials by component** Fabrics, coatings, plastics, foams, inks, adhesives and metal parts, with the supplier of each.
  * **Material supplier data** Safety data sheets and declarations from the fabric mill, compounder or coating supplier.
  * **Test reports for Annex XVII entries** From accredited labs, for the restrictions that apply to your product, such as PFHxA or formaldehyde release.
  * **Change notifications** A commitment to tell you before any material, supplier or process change.
  * **Re-confirmation after list updates** An updated declaration each time ECHA adds substances to the Candidate List.

How SourceSquid helps

## From your product list to an audit-ready file.

Our teams in Bengaluru and Ningbo collect the evidence at the factory, in the supplier’s own language, while production runs.

  1. 01

### Material mapping

Every SKU broken down into articles and materials, with the supplier behind each one.

You receiveMaterial and supplier map
  2. 02

### Risk-based screening

Substances likely in each material identified, so testing goes where it counts.

You receiveChemical risk matrix
  3. 03

### Lab testing

Samples drawn by our inspectors and sent to accredited labs in India or China.

You receiveTest plan and reports
  4. 04

### Declarations managed

Supplier declarations collected, checked and refreshed after every Candidate List update.

You receiveDeclaration register
  5. 05

### Article 33 and SCIP data

The information your customers and ECHA need, prepared per article.

You receiveCommunication-ready data
  6. 06

### Watch and alert

New restrictions and Candidate List changes mapped to your products.

You receiveCompliance Radar updates

Sources

## Official texts behind this page

Checked on 28 September 2026. This page explains the rules in plain English; for a view on your own products, ask our team or your legal adviser.

  1. [Regulation (EC) No 1907/2006 (REACH)](http://data.europa.eu/eli/reg/2006/1907/oj)Arts. 7(2), 7(7), 33, 57, 59, 67; Annex XVII
  2. [ECHA: Candidate List of substances of very high concern for Authorisation](https://echa.europa.eu/candidate-list-table)
  3. [Commission Regulation (EU) 2024/2462: PFHxA, its salts and related substances](http://data.europa.eu/eli/reg/2024/2462/oj)Annex XVII entry 79
  4. [Commission Regulation (EU) 2023/1464: formaldehyde and formaldehyde releasers](http://data.europa.eu/eli/reg/2023/1464/oj)Annex XVII entry 77
  5. [Directive (EU) 2018/851 amending the Waste Framework Directive (SCIP)](http://data.europa.eu/eli/dir/2018/851/oj)Art. 9(1)(i) of Directive 2008/98/EC
  6. [Court of Justice of the EU, Case C-106/14 (FCD and FMB)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:62014CJ0106)0.1% threshold applies to each article

Related compliance guides

## Rules that often travel together.

[EU · packaging**PPWR** Packaging and Packaging Waste Regulation (EU) 2025/40: conformity, substances, labels and recyclability.](https://sourcesquid.co/compliance/ppwr/)[DE · FR · EU**Packaging EPR** Extended producer responsibility in Germany (LUCID, VerpackDG) and France (Triman, IDU).](https://sourcesquid.co/compliance/epr/)[Management systems**ISO 9001 and 14001** Quality and environmental certification for suppliers, including the 2026 editions.](https://sourcesquid.co/compliance/iso-9001-14001/)

REACH questions

## Straight answers.

Dates checked against official sources. We update this page when the rules move.

[anirudh@sourcesquid.co](mailto:anirudh@sourcesquid.co)

### What is a REACH SVHC supplier declaration?

It is the supplier’s statement of whether an article contains any substance on ECHA’s Candidate List of substances of very high concern (SVHC) above 0.1% weight by weight, and if so which one. It supports the importer’s duty under Article 33 of REACH to pass that information on to customers, at minimum the substance name. A useful declaration names the Candidate List version it was checked against.

### Does the 0.1% SVHC threshold apply to the whole product or each part?

To each article. In Case C-106/14 (2015) the Court of Justice of the EU held that when a product is made of several articles, the 0.1% threshold applies to each article incorporated in it, not to the complex product as a whole. So a bag’s zip, strap and lining are each assessed.

### How quickly must I answer a consumer who asks about SVHCs?

Within 45 days of receiving the request, free of charge, if the article contains a Candidate List substance above 0.1% weight by weight. The answer must give enough information for safe use, including at least the name of the substance (Article 33(2)).

### When must an importer notify ECHA about an SVHC in articles?

When a Candidate List substance is present in its articles above 0.1% weight by weight and in quantities totalling over one tonne per importer per year, unless exposure can be excluded. The notification is due no later than six months after the substance is added to the Candidate List (Article 7(2) and 7(7)). Separately, suppliers of such articles provide the Article 33 information to ECHA’s SCIP database.

### What is the difference between the Candidate List and Annex XVII?

The Candidate List triggers information duties: communication, notification and SCIP. Annex XVII sets restrictions: substances that may not be placed on the market above set limits in certain products. For example, PFHxA is restricted in consumer clothing, footwear and food-contact paper from 10 October 2026, and furniture and other articles may not release formaldehyde above set limits since 6 August 2026.

Start here

## Chemical compliance, settled at the factory.

Send us your product list and materials. We return a REACH risk matrix and a test plan sized to what your products really need.

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