A Substance of Very High Concern is a substance identified by the European Chemicals Agency under EU REACH Article 57 as having serious effects on human health or the environment. The criteria include carcinogens, mutagens, reproductive toxicants (CMRs Category 1A or 1B), substances that are persistent, bioaccumulative, and toxic (PBTs), substances that are very persistent and very bioaccumulative (vPvBs), and substances giving rise to equivalent level of concern (typically endocrine disruptors). Once a substance is added to the SVHC Candidate List, downstream-user notification obligations kick in immediately. Listed substances can subsequently be moved to the REACH Authorisation List (Annex XIV), at which point EU customers need authorisation to continue using them.
The Candidate List vs the Authorisation List
| List | Purpose | Volume on list (approx 2026) | Effect |
|---|---|---|---|
| Candidate List | Substances identified as SVHC | ~240 entries | Notification + SCIP database obligations; supplier must inform downstream users; trigger for review for Authorisation listing |
| Authorisation List (Annex XIV) | SVHC substances requiring authorisation to use | ~60 entries | Sunset date after which use requires explicit ECHA authorisation; many uses simply cease |
Substances enter the Candidate List in semi-annual ECHA reviews. After typically 2 to 5 years on the Candidate List, ECHA may propose the substance for the Authorisation List. The Authorisation List specifies a “sunset date”, after that date, no use of the substance in the EU is permitted without an ECHA-granted authorisation for a specific use.
The authorisation process is expensive and slow. Most companies do not pursue authorisation for general industrial uses; they substitute the substance instead. SVHC listing is therefore a strong forward signal for product reformulation in EU supply chains.
The 0.1% notification threshold for articles
A key SVHC obligation: any article (a manufactured object, not a substance or mixture) supplied to the EU containing an SVHC at greater than 0.1% by weight triggers notification obligations to the recipient. The supplier must inform the recipient of the SVHC presence and provide enough information for safe use. The recipient may also have downstream notification obligations of their own.
For a chemical importer this matters less directly, chemicals are substances or mixtures, not articles. But it matters in two operational contexts:
- Packaging containing SVHC. Some packaging plasticisers, stabilisers, or surface treatments are SVHC. A drum lined with an SVHC-containing coating can trigger notification obligations.
- Products downstream of imported chemicals. A buyer importing a chemical that becomes part of an article (e.g. a phthalate plasticiser added to PVC products) triggers notification obligations on the article supply chain.
The SCIP database
Since January 2021, articles containing SVHC above 0.1% supplied to the EU market must be notified to the SCIP database (Substances of Concern In articles, as such or in complex objects). The notification includes substance identity, concentration band, location in the article, and disposal information. The data is publicly available, anyone can search SCIP to see which products contain which SVHCs.
For Chinese-origin articles entering the EU, the SCIP notification typically falls on the EU importer. The importer needs the SVHC content data from the Chinese supplier. This has driven a wave of supplier-side SVHC declarations from Chinese factories, most established suppliers can now produce an SVHC declaration on request.
How an SVHC listing affects Chinese-origin chemicals
When a substance is added to the SVHC Candidate List:
- Immediate effect: EU importers receive notification obligations. EU customers may demand SVHC content declarations from Chinese suppliers.
- 6-12 months out: EU customers begin reformulation evaluations to substitute the SVHC.
- 2-5 years out: ECHA proposes the substance for the Authorisation List. EU customers commit to substitution timelines.
- 5-7 years out: Sunset date passes. Substance use in the EU effectively ceases except for specific authorised uses.
For a Chinese factory whose substance is newly SVHC-listed, the EU market is on borrowed time. Volume declines start within 12 months. Within 5 years the EU market for the substance is likely closed for general industrial use.
Common SVHC categories from Chinese-export trade
A non-exhaustive sample of SVHC categories that have impacted Chinese-export trade significantly:
- Phthalate plasticisers (DBP, DEHP, BBP, DIBP and others), substituted across most EU PVC use
- Certain perfluorinated substances (PFAS), newer SVHC listings, accelerating substitution in EU surface-treatment supply chains
- Hexavalent chromium compounds. Authorisation List, severely restricted EU use
- Boron compounds (boric acid, sodium tetraborate), listed but with broad use exemptions
- Lead compounds, long-standing SVHC, Authorisation List for several specific salts
Chinese factories supplying these substances into the EU market have seen progressive volume erosion as the regulatory pressure tightens.
Cross-jurisdiction SVHC analogues
Several jurisdictions maintain analogue lists that overlap with EU SVHC:
- South Korea (under K-REACH) maintains Substances of Concern with significant SVHC overlap
- California Proposition 65 (state-level US) has overlap with SVHC carcinogen and reproductive toxicant categories
- China (under MEE rules) maintains a Priority Control list with growing overlap
- Australia (under AICIS) has begun mirroring some EU restrictions
For multi-jurisdictional supply, an EU SVHC listing is the leading indicator. Other jurisdictions catch up over 2 to 5 years.
Operator note: the SVHC-pivot for Chinese factories
Chinese factories with substances on the SVHC Candidate List often pivot to non-EU markets. Southeast Asia, Latin America, parts of Africa, where regulatory pressure is lower. For an EU buyer, this means the supplier base for the SVHC substance shrinks faster than the overall production capacity declines. Spot pricing can become volatile in the years between SVHC listing and Authorisation List sunset. Buyers needing the substance for that period should consider longer-dated supply contracts to lock in volume.
Related terms
REACH is the umbrella regulation under which SVHC sits. CLP classification feeds SVHC identification (CMR Category 1 substances are SVHC candidates). K-REACH is the closest cross-jurisdiction analogue. TSCA under the US has different mechanisms but covers some equivalent ground via the SNUR (Significant New Use Rule) framework.