ECHA updates its Candidate List for Substances of Very High Concern twice a year under Reg. (EC) No 1907/2006 (REACH), and as of early 2026 it stands at over 250 substances. Listing does not restrict use, but it activates a set of obligations that apply from the date of publication, with no transition period.
What applies from the date of listing
The most immediately consequential obligation comes from Article 33 of REACH. If your substance is present above 0.1% w/w in an article (not in a mixture), you are required to communicate that information down the supply chain to your customers, and to consumers upon request. The communication must include the substance name and enough information to allow safe use. There is no grace period: the obligation runs from the date of listing, which means companies that have not kept their substance screening current against the Candidate List can find themselves in breach within days of an ECHA update.
The consumer-facing side of Article 33 is worth noting separately. Under Article 33(2), any person supplying an article to a consumer must, upon request, provide information about Candidate List substance content within 45 days. For companies selling products directly to consumers, this creates an ongoing data management requirement that sits outside the usual B2B communication chain and is often not accounted for in standard compliance workflows.
Article 33 is not the only notification obligation activated by listing. Article 7(2) of REACH requires producers and importers of articles to notify ECHA directly if a Candidate List substance is present above 0.1% w/w and the total quantity of that substance across all articles produced or imported exceeds one tonne per year. Notification must be submitted within six months of the substance's inclusion on the Candidate List, via REACH-IT. This is separate from the Article 33 communication to customers and separate from any REACH registration. There is an exemption where the substance has already been registered under REACH for that specific use, including the relevant exposure scenarios. That exemption does not automatically extend to downstream producers of articles who have no registration on file covering that use.
ECHA publishes Article 7(2) notifications, and the non-confidential information from those submissions is searchable in its database. This means that if a customer or competitor queries ECHA for a substance, notifications already submitted will be visible. Companies that have not yet notified should be aware that third-party notifications for the same substance may already be in the database, which creates its own set of supply chain signals.
The same 0.1% w/w threshold also triggers notification to the SCIP database under the revised Waste Framework Directive (Directive 2008/98/EC, as amended by Directive 2018/851/EC). This is a distinct obligation from Article 33 and from REACH registration. It applies to EU suppliers of articles, including producers, importers, and distributors placing articles on the market, and its purpose is to carry substance information through to waste treatment. SCIP notifications are also publicly accessible, adding another layer of substance transparency that runs independently of the supply chain communication under Article 33.
For the substance itself, Article 31(1)(c) of REACH requires a Safety Data Sheet to be provided to downstream users and distributors where a substance is identified as SVHC and included on the Candidate List, even if it does not meet classification thresholds under Reg. (EC) No 1272/2008 (CLP). If you already supply an SDS because the substance is hazardous, Section 15 must be updated to explicitly reference the Candidate List status. If you were not previously required to supply an SDS, the Candidate List inclusion creates that obligation. The Section 15 update matters beyond documentation: customers further along the supply chain rely on that reference to meet their own Article 33 and SCIP obligations for articles they produce, which makes the SDS a functional link in a chain that reaches further than the immediate commercial relationship.
Mixtures and articles: where the obligations diverge
Article 33, SCIP notification, and Article 7(2) apply specifically to articles. A mixture — a formulated product such as an adhesive, lubricant, coating, or cleaning product — is subject to different requirements. Mixtures containing Candidate List substances do not trigger Article 33 or SCIP. For mixtures, Article 31(3) of REACH may require disclosure of SVHC content in the SDS when a substance is present at or above 0.1% w/w and that information is relevant for safe use. This is not an automatic disclosure trigger in the same way as Article 33 for articles, but where an SVHC is present at that level, the threshold for what counts as relevant for safe use is not high. CLP labelling requirements apply separately, based on classification, not Candidate List status.
The distinction matters because many substances cross this boundary within a supply chain. The substance may be sold as a chemical input (Article 31 applies), incorporated into a mixture (Article 31 applies at the formulation stage), and then used to produce or become part of an article (Article 33 and SCIP apply at that stage). A cured sealant in a building component, a plastic part containing a plasticiser, a coated metal fastener: these are all articles. The fact that they originated as mixtures during processing does not change their status as articles once they are part of a finished product with a defined shape and function.
Companies supplying substances or mixtures to customers who then manufacture articles carry an indirect exposure here. Their customers' Article 33, SCIP, and Article 7(2) compliance depends partly on receiving timely and accurate SVHC information through the SDS. A delayed or incomplete Section 15 update does not stay contained at the formulation stage.
The authorization trajectory
Candidate List inclusion is the formal starting point for potential authorization under REACH Title VII. Substances recommended by ECHA for inclusion in Annex XIV, the Authorization List, become subject to a sunset date after which they cannot be used or placed on the market without a granted authorization, unless a use is specifically exempted.
Authorization is not a straightforward process. An applicant must submit an analysis of alternatives, a socioeconomic analysis justifying continued use where technically and economically viable substitutes are absent, and a substitution plan where alternatives are emerging. ECHA's RAC and SEAC review the application and issue opinions, after which the European Commission decides. Authorizations are use-specific and time-limited, with a mandatory review before the authorization period expires. From application to Commission decision, the process runs over multiple years and requires regulatory expertise and socioeconomic modeling, which is why many companies facing Annex XIV substances conclude that substitution is the more workable path.
Not every Candidate List substance gets recommended for Annex XIV. Priority is given based on volume, dispersive use, and the availability of alternatives. Getting a substance onto Annex XIV can take anywhere between two years and well over a decade. For substances embedded in regulated product categories such as medical devices, food contact materials, cosmetics, or specialized industrial applications with long qualification cycles, the planning horizon for substitution or reformulation needs to account for that uncertainty rather than treat a slow process as an absent one.
The commercial dynamic often moves well ahead of the formal regulatory timeline. OEMs and large industrial customers frequently maintain their own Restricted Substances Lists that go beyond the REACH Candidate List, and a new SVHC addition can prompt voluntary phase-out decisions at the customer level well before ECHA has begun any prioritization assessment. For suppliers of specialty chemicals or compounded materials, that commercial signal is often the more pressing one, arriving faster and with more concrete procurement consequences than the regulatory calendar.
What your customers are already asking
For many companies, the first sign that a substance has been listed comes not from ECHA but from a customer questionnaire, a supplier declaration request, or an updated SDS requirement arriving in the inbox. Customer compliance teams screen their supply chains against the Candidate List on a regular basis, and their requests often arrive before a company has updated its own internal screening.
The information they need is specific: substance identity (EC number, CAS number, IUPAC name), location within the article, concentration range, and safe handling guidance. Being able to provide that promptly, or to confirm documented absence with a clear basis, is what determines whether a supplier inquiry is straightforward to resolve or becomes a drawn-out back-and-forth.
For supply chains involving articles sold into automotive, electronics, or construction markets, the downstream requirements often go beyond REACH itself. The electronics sector operates under the IEC 62474 material declaration standard, and automotive supply chains use IMDS (the International Material Data System), both of which track substances independently of REACH timelines and with their own threshold and reporting logic. Customers in those sectors can contractually require substance declarations that are more detailed and more frequently updated than the SCIP or Article 33 obligations standing alone, which means REACH compliance is the floor, not the ceiling.
What listing does not decide
Candidate List status does not mean a substance will be restricted under Annex XVII of REACH, nor does it retroactively change registration requirements. A substance already registered under REACH does not need to be re-registered because of Candidate List inclusion. If registration was not previously required (for example, because use volumes sit below the 1 tonne per year threshold per registrant), that exemption remains in place.
Where listing does intersect with existing registrations is in the chemical safety report. Where the SVHC identification introduces new or previously unassessed hazard information, the registration may need to be updated to reflect that assessment. This is particularly relevant for substances added under the equivalent level of concern pathway in Article 57(f) of REACH, which covers endpoints such as endocrine disruption or respiratory sensitization that were not always fully evaluated in earlier-generation dossiers. A Candidate List inclusion under Article 57(f) can expose gaps in a chemical safety report that registration itself did not surface.
The listing also does not change the substance's classification under CLP. Classification and Candidate List status operate under different criteria and different procedures. A substance can be SVHC without carrying a harmonised classification under CLP Annex VI, and many classified substances have not been identified as SVHC. The overlap exists, as carcinogenicity, mutagenicity, reprotoxicity, PBT, vPvB, and equivalent level of concern are SVHC grounds that often align with CLP hazard categories, but the two determinations are made independently and updated on different schedules.
If you are working through what a new Candidate List addition means for your substance, your articles, or your supply chain documentation, we are happy to help you map it out. Get in touch.