REGULATIONSREACH

REACH

Your duty is real and sits on you as the EU importer, unless your supplier has appointed an only representative to carry it.

FALLS ONSUPPLIERBUYER

This one falls on both of you. Your supplier owes an Article 33 communication in their own right.

THE OFFICIAL ARTIFACT

What the supplier must actually produce.

Not a generic safety sheet. A current SDS on the Annex II format, plus the SVHC communication the article itself triggers.

WHO SIGNS IT OFF
Nothing is filed to a portal. The safety data sheet and the Article 33 information travel with the product; ECHA notifications are yours to submit.
REQUIRED ARTIFACT · REACH6 ELEMENTS
Safety data sheet + Article 33 communication
REG. (EC) 1907/2006 · ART. 31, 33 · ANNEX II (2020/878)
Sixteen-section SDSOn the Annex II format as amended by Regulation 2020/878.
Substance identity and concentrationPer substance, at the level the classification requires.
SVHC content above 0.1%Determined per article, not across the finished assembly.
Article 33 communicationAutomatic to business recipients; within 45 days to consumers on request.
Safe-use informationEnough for the recipient to handle the article safely.
SDS updatesRe-issued to anyone supplied in the previous twelve months when new information arises.
THE CHARACTERISTIC FAILURE

An SDS for the finished product arrives.

A safety data sheet arrives where per-article substance data was needed.

WHAT USUALLY ARRIVESINSUFFICIENT
SDS for the finished assembly
SUPPLIER-ISSUED · 16 SECTIONS · CURRENT FORMAT
Correct format, correctly completed
Concentrations averaged across the whole product
SVHC below 0.1% of total mass, so nothing declared
NOT SUFFICIENT
A valid SDS on the wrong denominator. Article 33 measures the substance against each article, where the same substance can exceed the threshold.
WHAT THE REGULATION NAMESSUFFICIENT
Per-article SVHC determination
PER ARTICLE · 0.1% W/W · CANDIDATE LIST RE-SCREENED
Concentration calculated per article within the assembly
Named SVHCs with safe-use information
Re-checked at each Candidate List update
SUFFICIENT
Same product, same substances — measured against the article the regulation names.
THE DELTA: AVERAGED OVER THE ASSEMBLY VS MEASURED PER ARTICLE
NEXT MILESTONE · REACH
LAST VERIFIED 9 AUG 2026
NowIN FORCE
IN FORCECONTINUOUS SINCE 2007
Candidate list updated twice yearly

There is no deadline to count to. The obligation moves when the SVHC candidate list moves, and a substance in your part can cross the 0.1% w/w line without you touching the product.

Does REACH reach your products?

Find out which articles in your range carry a candidate-list substance above 0.1%.

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