Factories targeting the Spanish market, pay attention. Recently, several customers have asked me: the goods have already arrived at the Port of Valencia, but during customs clearance they were asked to provide a REACH SVHC screening report. They could not produce it, and the goods are stuck at the dock burning money every day. This is nothing new, but every time, some factory still trips up on it. As an EU member state, Spain treats the REACH regulation as a hard threshold, and SVHC is the hurdle within it that is easiest to overlook. Simply put, SVHC is the "Substances of Very High Concern" list, which the European Chemicals Agency (ECHA) updates regularly, and the list now contains more than 200 substances. As long as your product contains an SVHC substance at a concentration exceeding 0.1%, you must communicate information downstream to customers and consumers, otherwise it is non-compliant.
So which products need this screening? Do not assume only chemical products are involved. Plastic parts, rubber parts, coatings, inks, adhesives, textiles, electronic and electrical enclosures, and even packaging materials are all within scope. Spanish customers are especially strict; many purchasers will directly require you to provide an SVHC screening report before they are willing to place an order. The three most common pitfalls are: first, thinking that doing RoHS means you do not need to worry about SVHC. They are two different things. RoHS governs restricted substances, while SVHC governs the duty to inform. Second, focusing only on the finished product and forgetting the raw materials and auxiliary materials upstream in the supply chain, such as the flame retardants in a certain plastic part or the solvents in ink, which are often the source of exceedances. Third, fobbing people off with an old report. The SVHC list is updated twice a year. If you provide a report from three years ago, the customer will send it back at a glance.
Now for the timeline. SVHC screening is not just a matter of issuing a certificate; it is essentially testing plus assessment. You need to disassemble the product into homogeneous materials and send them to a laboratory for screening, which usually takes 5 to 7 working days. If complex assemblies are involved or a supply chain investigation is needed, the time will be longer. If an exceedance is detected, you will also need to adjust the formulation or change suppliers, and then the timeline becomes even less predictable. So do not wait until orders arrive to scramble for last-minute solutions. Sort out the BOM in advance and have suppliers provide material declarations, which can save a lot of trouble.
One final reminder: Spanish customers are very rigid about compliance documents, so do not think you can muddle through. An SVHC screening report is not a "guaranteed pass" transaction; it reflects the true compliance status of your product. Do it early, rather than scrambling to fix things after the goods reach the port.