REACH 251 SVHC

The REACH (Registration, Evaluation, Authorization and Restriction of Chemicals) regulation is the European Union's comprehensive framework for the management of chemical substances, established under Regulation (EC) 1907/2006. Its aim is to protect human health and the environment by ensuring proper control of risks posed by chemicals.

One of the key elements of REACH is the candidate list of substances of very high concern (SVHCs). These are defined as substances that have the potential to cause serious and often irreversible effects. For example,

• Carcinogenic
• Mutagenic
• Toxic to reproduction (collectively CMR category 1A or 1B)
• Persistent, bioaccumulative, and toxic.
• Very persistent and highly bioaccumulative.
• Or substances of equivalent concern (e.g., endocrine disruptors).

Substances proposed for inclusion in the Candidate List are subject to public consultation and review (usually by ECHA's member state committee). Once included, these substances become SVHCs (very high-risk chemicals), and companies immediately face legal liabilities.

According to the last update in 2025, the candidate list has reached 251 substances (the actual number of individual substances covered is higher, as some substances represent their respective chemical groups).

ECHA typically updates the list about twice a year, but additional updates may occur.

If a substance, mixture, or article (a final product with a specific shape/function, e.g., electronics, textiles, toys, machinery) contains an SVHC (very hazardous substance) in a concentration exceeding 0,1% by weight:

• Communication in the supply chain: Suppliers must inform buyers (and consumers upon request within 45 days) of the presence of SVHCs and provide information on safe use.
• Notification to ECHA: Importers/producers of articles must notify ECHA within 6 months of inclusion in the list if the SVHC content exceeds 0,1% and the total amount exceeds 1 tonne per producer/importer per year. Notifications are recorded in the database of substances of concern in articles under the Waste Framework Directive.
• Safety data sheets: Required for substances/mixtures containing very hazardous substances (SVHCs).
• Other implications: products containing more than 0,1% SVHC are not eligible for the EU eco-label; their future inclusion in the authorization list may require authorization for continued use, or restrictions may prohibit their use.

Non-compliance can lead to enforcement actions, fines, market withdrawals, reputational damage, and supply chain disruptions. Companies offering products to the EU market must monitor updates, control their supply chains, request declarations from suppliers, and conduct risk assessments or tests where necessary. The list continues to grow as more substances are assessed, reflecting the EU’s ongoing efforts toward safer chemicals.

In short, REACH 251 SVHC refers to the candidate list of substances of very high concern (SVHCs) under the EU's REACH regulation, and the latest update (2025) is a significant milestone, as the candidate list continues to expand, reflecting the EU's ongoing efforts to identify and control the most hazardous chemicals.

The candidate list is a fundamental mechanism of REACH, designed to protect human health and the environment from substances that can cause serious, often irreversible harm.

Inclusion on the list indicates that a substance may eventually require authorization (or face restrictions) before it can continue to be used on the EU market. The fact that the list has reached 251 substances (the total number of individual substances affected is higher as some substances cover related chemical groups) demonstrates accelerating regulatory scrutiny, particularly on persistent flame retardants, silicones and other industrial chemicals.

The main reasons why REACH 251 SVHCs are important are as follows:

• It triggers immediate legal liabilities for companies when a substance, mixture, or product (any finished product with a specific shape, surface, or design, such as electronics, textiles, toys, vehicles, furniture, or machinery) contains more than 0,1 percent by weight of SVHC (very hazardous chemical):
• Supply chain communication: Suppliers must inform downstream buyers about the presence of SVHCs and provide safe handling instructions. Consumers can request this information within 45 days.
• Notification to ECHA: Manufacturers and importers of products must notify ECHA within 6 months of their inclusion if the total quantity exceeds 1 tonne per year. These notifications are entered into a database of substances of concern found in publicly available products or complex objects/products, enabling waste operators, recyclers, and authorities to safely handle end-of-life products.
• Security data sheet updates and other reporting requirements apply.

Non-compliance may lead to fines, product recalls, market bans or enforcement actions across the EU/EEA.

• Market access and business risks: Products containing more than 0,1% SVHC are not eligible for the EU Eco-label and may face green/public procurement barriers. Many global brands and retailers require REACH SVHC compliance in supplier contracts, even outside the EU. Inclusion often precedes further restrictions or authorization requirements. In this case, uses may be banned after an expiry date unless companies obtain an expensive, time-bound authorization and can prove that safer alternatives do not exist.
• Supply chain transparency and substitution pressure: The list forces companies to scrutinize materials, request declarations from suppliers, conduct tests, and phase out SVHCs in favor of safer alternatives. This supports the EU’s chemicals for sustainability strategy (part of the European Green Deal), which aims to minimize exposure to the most harmful substances and promote innovation in green chemistry.
• Broader societal and environmental impact: This list helps reduce long-term pollution, bioaccumulation in wildlife/food chains, and health risks (e.g., cancer, reproductive problems, or ecosystem damage).

In short, REACH 251 SVHC is a regulatory threshold that triggers compliance obligations, drives supply chain due diligence, influences product design, and advances the EU’s non-toxic environment objective. Companies placing products on the EU market (or supplying to EU customers) should closely monitor ECHA updates as the list is expected to continue growing.

For many years, our organization, with its competent and experienced team, has been understanding the needs of its clients, providing the advanced testing services they require, and assisting them in the establishment, implementation, and improvement of management systems. Within this framework, we also provide testing services compliant with the REACH 251 SVHC list.