Bottom line:
The main causes of returns due to SVHC exceeding limits are threshold calculation and missing supply chain information. Article 33 of REACH Regulation (EC) No 1907/2006 requires that when the SVHC content in an article exceeds 0.1% (by weight), the supplier must provide sufficient information to the recipient for safe use. According to public industry data, returns caused by SVHC exceeding limits or missing information transmission account for a relatively large proportion of chemical compliance return cases for exports to the EU. The rectification period is usually 5–10 working days (reference range), and the cost is 2,500–9,000 yuan (reference range), depending on the number and complexity of testing items."
Threshold calculation: Is the 0.1% for homogeneous materials or the entire article? The 0.1% threshold in Article 33 of REACH applies to homogeneous materials in an article, not the entire finished product. For example, if the SVHC content in a certain plastic component of an electronic product housing exceeds 0.1%, the information transmission obligation is triggered. Common company errors include: - Calculating by the weight of the entire product, resulting in underestimation of risk; - Failing to identify all homogeneous materials (such as coatings, inks, and solder); - Confusing the rules for articles and mixtures. It is recommended to establish a list of homogeneous materials and screen high-risk materials (plastics, rubber, coatings, electronic solder).
2026 SVHC list and self-check key points for declaration As of 2026, the SVHC list has included more than 200 substances (subject to the latest official ECHA list). Companies should focus on the following in self-checks: 1. List updates: Regularly check the ECHA official website to ensure the latest version is used; 2. Supply chain communication: Require upstream suppliers to provide SVHC declarations or test reports; 3. Testing methods: Select appropriate pretreatment and instrumental analysis (such as GC-MS, ICP-MS) based on homogeneous materials; 4. Document retention: Keep test reports and supply chain declarations for at least 10 years. The table below shows common high-risk materials and recommended testing items (reference range):
Plastics — Common SVHC substances: Phthalates, polycyclic aromatic hydrocarbons; Reference testing period (working days): 5–7; Reference cost (yuan): 2,500–5,000
Coatings/inks — Common SVHC substances: Heavy metals, organotin; Reference testing period (working days): 5–7; Reference cost (yuan): 3,000–6,000
Electronic solder — Common SVHC substances: Lead, cadmium; Reference testing period (working days): 5–10; Reference cost (yuan): 4,000–9,000
Textiles — Common SVHC substances: Azo dyes, flame retardants; Reference testing period (working days): 5–10; Reference cost (yuan): 3,000–8,000
Note: The above are public industry reference ranges; actual quotes and scheduling are subject to the cooperating laboratory.
Rectification path: from exceeding limits to compliance If testing finds that SVHC exceeds the limit, companies can take the following steps: 1. Confirm the substance and content exceeding the limit: Check the test report to confirm whether it exceeds 0.1%; 2. Evaluate alternatives: Communicate with suppliers about replacing materials or adjusting formulations; 3. Information transmission: If substitution is not possible, provide safe use instructions to downstream customers; 4. Retesting: After rectification, conduct verification testing on the relevant homogeneous materials. It should be noted that the platform does not engage in testing activities; testing is completed by qualified cooperating laboratories, and reports are issued by them.
Connection with customer audits Many EU customers require suppliers to provide a REACH Declaration of Conformity (DoC) or test reports. It is recommended that companies incorporate SVHC screening into the new product introduction process and update it regularly. For complex products, self-check templates can be obtained from the REACH topic page at shuwang-cert.com.
The takeaway:
The key to REACH-SVHC compliance is correctly calculating the 0.1% threshold by homogeneous material and establishing a supply chain information transmission mechanism. Advance self-checks and testing can keep the rectification period within the reference range of 5–10 working days and avoid goods being returned.
Our practice is to issue an applicability table first, so the testing scope is fixed before anything else is quoted.
Prepared by the Shuwang certification engineering team from live project records.
Service boundary: Shuwang Certification Platform is an export certification solution provider. It does not perform testing and is not a certification body. Testing described on this page is carried out by partner laboratories accredited to CNAS/CMA or ISO/IEC 17025; certificates are issued by EU Notified Bodies or by the authorised bodies of the destination country. Lead times and cost ranges are public industry references and depend on engineer assessment and body scheduling.