SVHC Substances Under REACH: What EHS Managers Need to Know

Substances of Very High Concern (SVHC) represent the highest tier of chemical risk under EU law. For EHS managers, procurement teams, and downstream users, SVHC status triggers a cascade of legal obligations that go well beyond standard GHS labelling.

This guide explains what SVHC means in practice, how it connects to GHS hazard classification, and what your organisation must do when SVHC substances are present in your products or workplace.

What Is an SVHC?

Under the REACH Regulation (EC) No 1907/2006, a substance may be identified as an SVHC if it meets one or more of the following criteria:

Criterion	Definition	Typical GHS link
CMR Cat 1A/1B	Carcinogenic, mutagenic, or toxic to reproduction	H340, H350, H360
PBT	Persistent, Bioaccumulative, and Toxic	H400/H410 + toxicity
vPvB	Very Persistent and very Bioaccumulative	No direct GHS code
Endocrine disruptor	Disrupts hormonal systems (human or environment)	H362 or environmental
Equivalent concern	Case-by-case ECHA scientific assessment	Varies

The key point: not all SVHC substances have obvious GHS hazard pictograms. A vPvB substance may carry only GHS09 (environmental hazard) or even no pictogram at all — yet still trigger full REACH notification obligations.

The SVHC Candidate List

ECHA maintains the Candidate List of Substances of Very High Concern for Authorisation. As of early 2026, the list contains over 240 substances.

The Candidate List is updated twice per year (typically June and January). Each update may add new substances or revise existing entries.

Key substances on the Candidate List include:

Substance	CAS Number	SVHC reason	GHS pictograms
Lead and lead compounds	7439-92-1	CMR 1A (repro)	GHS08, GHS09
Bisphenol A (BPA)	80-05-7	Endocrine disruptor	GHS07, GHS08
Formaldehyde	50-00-0	CMR 1B (carc/muta)	GHS02, GHS06, GHS08
Cadmium	7440-43-9	CMR 1B + PBT	GHS06, GHS08, GHS09
Dimethylformamide (DMF)	68-12-2	CMR 1B (repro)	GHS02, GHS07, GHS08
DEHP (plasticiser)	117-81-7	CMR 1B (repro)	GHS08
Chromium VI compounds	Various	CMR 1A (carc)	GHS05, GHS06, GHS08
Arsenic trioxide	1327-53-3	CMR 1A (carc)	GHS06, GHS08, GHS09

Always check the current list at ECHA Candidate List — substances are added regularly.

From Candidate List to Authorisation List

The SVHC process has two stages:

Stage 1: Candidate List

Substance is identified as SVHC. Notification and communication obligations apply immediately.

Stage 2: Authorisation List (Annex XIV)

Substance is added to Annex XIV. Use is prohibited after the sunset date unless authorisation is granted by ECHA.

The transition from Candidate List to Authorisation List is not automatic — ECHA prioritises substances based on volume, exposure, and risk. However, EHS managers must act from Candidate List inclusion, not from Annex XIV.

Legal Obligations Triggered by SVHC Status

1. Article 33 — Duty to Communicate (Supplier to Customer)

If your article contains an SVHC substance above 0.1% by weight, you must:

Inform your business customers upon request within 45 days
Inform consumers upon request within 45 days (free of charge)
Provide at minimum: the name of the SVHC substance

This applies to finished articles (e.g. plastic components, electronic parts, coatings) — not just bulk chemicals.

Example: A manufacturer of rubber seals uses DEHP as a plasticiser at 1.2% by weight. The seal is an article. Every customer who asks must receive notification that DEHP (an SVHC) is present above 0.1%.

2. Article 7(2) — Notification to ECHA

If your company produces or imports articles containing an SVHC:

Above 0.1% by weight of the article, AND
In quantities exceeding 1 tonne per year per substance

You must notify ECHA via the SCIP database.

3. SCIP Database Notification

Since 5 January 2021, all producers and importers of articles containing SVHC above 0.1% must submit information to the SCIP database (Substances of Concern In articles, as such or in complex Products).

SCIP notifications must include:

Article identifier (EAN, part number, or similar)
SVHC substance identity (name + CAS)
Concentration range
Safe use information

Failure to notify SCIP is an infringement of REACH enforced at national level.

4. Safety Data Sheet Requirements

If the substance is on the Candidate List, Section 15 of the SDS must explicitly state SVHC status and Candidate List inclusion — even if the substance does not require a full SDS under other criteria.

SVHC vs GHS Classification: Key Differences

This is where many EHS professionals make errors. GHS classification and SVHC status are separate systems that partially overlap:

Situation	GHS Label	SVHC obligations
CMR Cat 1A/1B substance	GHS08 required	SVHC Candidate List likely applies
vPvB substance, low acute toxicity	GHS09 or none	SVHC Candidate List may apply
PBT substance	GHS09 typically	SVHC Candidate List likely applies
Endocrine disruptor, low acute tox	Minimal GHS	SVHC Candidate List applies
Substance with GHS08 only (STOT)	GHS08 required	May NOT be SVHC

Critical point: A substance can have significant GHS hazard pictograms but not be on the Candidate List. Conversely, a substance with no GHS08 pictogram may still be an SVHC due to environmental persistence.

Always check both systems independently.

Practical Checklist for EHS Managers

Use this checklist when reviewing chemical inventory or onboarding new substances:

Step 1: Identify SVHC presence

Cross-reference all substances against current ECHA Candidate List
Check SDS Section 15 for explicit SVHC statement
Do not rely on GHS pictograms alone — check vPvB and endocrine disruptor criteria

Step 2: Assess concentration

Determine weight % of SVHC in each article and mixture
Apply 0.1% threshold separately to each article (not the whole product)
Document calculations and methodology

Step 3: Fulfil communication obligations

Establish customer notification procedure (Article 33 response within 45 days)
Update product documentation and website if consumer-facing
Train sales and customer service teams on Article 33 responses

Step 4: SCIP database

Register for ECHA REACH-IT account if not already done
Submit SCIP notifications for all qualifying articles
Set calendar reminder for Candidate List updates (June and January)

Step 5: Review Authorisation List (Annex XIV)

Check if any SVHC substances in use are on Annex XIV
Identify sunset dates for Annex XIV substances
Begin substitution assessment or authorisation application if required

Substitution: The Preferred Option

For substances on the Authorisation List, ECHA strongly prefers substitution over authorisation. The socio-economic analysis required for authorisation is complex and expensive.

For Candidate List substances, substitution is not legally required but represents best practice under REACH’s substitution principle.

Substitution assessment steps:

Identify the function of the SVHC in the product
Screen alternative substances using ECHA’s Substitution Support Portal
Assess alternatives for technical feasibility, cost, and their own hazard profile
Document the assessment — even if substitution is not feasible at this time

Key Resources

Tools for EHS Professionals

🔍 Search our substance database — Check GHS classification for 4,000+ substances including CMR and SVHC-relevant compounds
⚗️ ATE Calculator — Calculate acute toxicity estimates for mixtures containing CMR components
🏪 Chemical Storage Matrix — Check segregation requirements for SVHC substances in your warehouse

This article is for informational purposes only and does not constitute legal advice. SVHC obligations depend on your specific role in the supply chain. Consult a REACH regulatory specialist for authorisation applications or complex supply chain scenarios.