| EU law | Regulation (EC) No 1907/2006 (REACH), as amended. Administered by the European Chemicals Agency (ECHA) |
| GB law | UK REACH: the REACH Regulation as it applies in Great Britain from 1 January 2021, amended by the REACH etc. (Amendment etc.) (EU Exit) Regulations 2019 (SI 2019/758) and later instruments. HSE is the Agency |
| Northern Ireland | EU REACH continues to apply |
| Lists | Separate EU and UK Candidate Lists of substances of very high concern (SVHCs) |
| Related pages | RoHS (GB and EU), UKCA and CE marking, WEEE |
What it covers
REACH regulates chemical substances on their own, in mixtures and in articles. An article is an object which during production is given a special shape, surface or design which determines its function to a greater degree than does its chemical composition.
UK REACH and EU REACH operate independently. HSE states that businesses must comply with both where necessary. UK REACH covers Great Britain. Under the Northern Ireland Protocol, EU REACH continues to apply in Northern Ireland.
The Candidate List
SVHCs are identified under Article 57 and Article 59. They include substances that are carcinogenic, mutagenic or toxic for reproduction (category 1A or 1B), persistent, bioaccumulative and toxic (PBT), very persistent and very bioaccumulative (vPvB), or of equivalent concern. Identified SVHCs go on the Candidate List.
- ECHA keeps the EU Candidate List. HSE keeps the UK REACH Candidate List.
- When UK REACH came into force, all substances on the EU list were carried over to the UK list. Since then the two lists have been updated separately.
- From 24 February 2026 the UK government’s approach is to review substances added to the EU list since 1 January 2021, and later EU additions, and add them to the UK list where appropriate. A substance can therefore be on one list and not yet on the other.
Duties for SVHCs in articles
| Duty | Trigger | What is required |
|---|---|---|
| Article 33(1): inform recipients | Article contains a Candidate List SVHC above 0.1 % w/w | Give the recipient enough information for safe use, as a minimum the name of the substance |
| Article 33(2): consumer requests | As above, on request from a consumer | Provide the same information free of charge within 45 days of the request |
| Article 7(2): notification | SVHC above 0.1 % w/w in the article and over 1 tonne per year per producer or importer | Notify ECHA (EU) or HSE (GB) no later than 6 months after the substance is added to the list. Not needed where exposure can be excluded during normal or reasonably foreseeable conditions of use including disposal. In that case appropriate instructions must be supplied to the recipient (Article 7(3)) |
| SCIP (EU only) | Article contains a Candidate List SVHC above 0.1 % w/w | Submit the Article 33(1) information to ECHA, required from 5 January 2021 |
Notifications in GB are made through the Comply with UK REACH service.
The 0.1 % threshold: CJEU ruling of 2015
In Case C-106/14 (judgment of 10 September 2015), the Court of Justice of the EU ruled that the 0.1 % threshold applies to each article incorporated as a component of a complex product, not to the product as a whole.
- An object that meets the definition of an article does not stop being an article when it is assembled or joined with other objects into a complex product. It remains an article as long as it keeps the shape, surface or design that determines its function and does not become waste (paragraph 53 of the judgment).
- For Article 33, a supplier of a product in which one or more component articles contain an SVHC above 0.1 % of that article’s mass must inform the recipient, and consumers on request, giving at least the substance name.
- For Article 7(2), an importer of a product made up of more than one article must assess each article against the 0.1 % threshold.
SCIP database
SCIP is ECHA’s database of substances of concern in articles. It comes from Article 9(1)(i) of the EU Waste Framework Directive (2008/98/EC as amended), which requires Member States to ensure that suppliers of articles provide their Article 33(1) information to ECHA from 5 January 2021. ECHA gives access to the data to waste treatment operators and, on request, to consumers.
Annex XVII: lead in PVC
Commission Regulation (EU) 2023/923 of 3 May 2023 (published 8 May 2023) added paragraphs 15 to 20 to entry 63 (lead and its compounds) of Annex XVII to EU REACH.
| Provision | EU requirement |
|---|---|
| Restriction (para 15) | Lead must not be present in PVC articles at 0.1 % or more by weight of the PVC material |
| Start date (para 16) | 29 November 2024 |
| Recovered flexible PVC (para 17) | Derogation ended 28 May 2025 |
| Recovered rigid PVC (para 18) | Below 1.5 % lead in the recovered rigid PVC allowed until 28 May 2033 in listed uses, including profiles and sheets in concealed spaces such as cable ducts. Such articles with 0.1 % or more lead must be marked “Contains ≥ 0,1 % lead” |
| Excluded articles (para 19) | Articles within the scope of the RoHS Directive 2011/65/EU, food contact materials, packaging and toys, among others |
| Existing stock (para 20) | Does not apply to PVC articles placed on the market until 28 November 2024 |
Paragraph 19(c)(ii) excludes articles within the scope of the RoHS Directive 2011/65/EU.
In GB, entry 63 of UK REACH Annex 17, as published on legislation.gov.uk, contains no equivalent lead in PVC provision.
Related reading: PVC vs PUR cable: which jacket to use where.