REACH SVHC & SCIP Compliance 2026

A Practical Regulatory Guide for EU Market Access and Circular Economy Readiness

The EU REACH Regulation (EC) No 1907/2006 remains one of the most comprehensive chemical regulatory frameworks globally. As regulatory enforcement tightens and sustainability expectations rise across Europe, REACH SVHC compliance and SCIP database reporting have become non-negotiable obligations for companies placing articles on the EU and EEA markets.

With increased inspections, digital traceability expectations, and circular economy enforcement through 2026, organizations must treat SVHC identification, Article 33 communication, and SCIP notification as strategic compliance pillars not administrative afterthoughts.

At Maven Regulatory Solutions, we help global manufacturers and suppliers build inspection-ready, future-proof REACH and SCIP compliance programs aligned with evolving EU regulatory priorities.

Understanding REACH and Its Regulatory Purpose

REACH stands for:
Registration, Evaluation, Authorization and Restriction of Chemicals

Its primary objectives are to:

• Protect human health and the environment
• Increase transparency of chemical hazards
• Promote safe use of substances
• Support substitution of hazardous chemicals
• Enable circular economy and sustainable product design

Two of the most compliance-critical elements under REACH for product manufacturers are:

1. Substances of Very High Concern (SVHC) obligations
2. SCIP database notifications

What Are Substances of Very High Concern (SVHCs)?

SVHCs are substances identified as posing serious and often irreversible risks to human health or the environment.

SVHC Hazard Categories

SVHCs typically fall into one or more of the following groups:

SVHC Classification Under REACH

Once identified, SVHCs are added to the REACH Candidate List, which is updated twice per year by ECHA.

2026 Regulatory Reality:
Candidate List updates increasingly trigger immediate supply chain reviews, especially in electronics, automotive, packaging, medical devices, and consumer goods.

Why the REACH Candidate List Matters

When a substance is added to the SVHC Candidate List, it immediately triggers legal obligations for companies placing substances or articles on the EU market.

Failure to act can result in:

• Regulatory enforcement actions
• Market access disruption
• Customer rejection
• Brand and ESG risk

SVHC Communication Obligations (REACH Article 33)

Under REACH Article 33, suppliers must communicate SVHC information when:

• An article contains an SVHC > 0.1% weight by weight (w/w)

What Must Be Communicated?

Suppliers must provide:

• Name of the SVHC
• Information sufficient to allow safe use
• Information to downstream users and distributors

Consumer Rights

• Consumers may request SVHC information
• Response required within 45 days
• Information must be provided free of charge

Article 33 Communication Requirements

REACH Article 7(2): ECHA Notification Duty

In addition to communication, ECHA notification is required when:

• SVHC concentration > 0.1% w/w and
• Total SVHC quantity exceeds 1 ton per year per legal entity

This ensures regulatory authorities can:

• Track high-risk substances
• Assess exposure patterns
• Inform future restrictions or authorization decisions

Introduction to the ECHA SCIP Database

The SCIP database was introduced under the revised EU Waste Framework Directive (WFD) to support the EU Circular Economy Action Plan.

SCIP stands for:
Substances of Concern In articles as such or in complex objects (Products)

SCIP Objective

• Improve chemical transparency across the product lifecycle
• Support safer recycling and waste management
• Enable informed substitution of hazardous substances

SCIP Notification Requirements (Mandatory Since 5 January 2021)

From 5 January 2021 onward, any company placing articles on the EU/EEA market must submit a SCIP notification if:

• The article contains an SVHC > 0.1% w/w
• No minimum tonnage threshold applies

SCIP vs REACH Notification

Who Must Submit SCIP Notifications?

Affected entities include:

• EU manufacturers of articles
• EU importers of articles
• Assemblers of complex objects
• Distributors placing products on the EU market

SCIP Submission Must Include:

• Article identification
• SVHC name(s)
• Concentration range
• Material category
• Safe use instructions
• Links to complex objects (where applicable)

Why REACH SVHC & SCIP Compliance Matters in 2026

Regulators increasingly view chemical transparency as a core sustainability obligation, not just regulatory compliance.

Key 2026 Drivers:

• Increased ECHA enforcement
• Digital product passports (DPP)
• ESG and sustainability reporting alignment
• Supply chain traceability
• Waste and recycling controls

Business Impact of Non-Compliance

Common Compliance Gaps Observed

• Missing Candidate List updates
• Incorrect 0.1% threshold calculations (per article vs complex object)
• Incomplete SCIP datasets
• Poor supply chain SVHC data collection
• No internal ownership of chemical compliance

How Maven Regulatory Solutions Supports REACH & SCIP Compliance

Maven Regulatory Solutions provides:

• SVHC screening and Candidate List monitoring
• Article-level threshold assessments
• REACH Article 33 communication frameworks
• SCIP dossier preparation and submission
• Supply chain data governance models
• Readiness and audit defense

FAQs: REACH SVHC & SCIP Compliance

Is SCIP separate from REACH?
Yes. SCIP is legally linked to REACH SVHCs but established under the Waste Framework Directive.

Does SCIP replace Article 33 communication?
No. Both obligations apply independently.

Are complex objects assessed as a whole?
No. The 0.1% threshold applies per article, not the final product.

Do non-EU companies have SCIP obligations?
Yes, if they place articles on the EU market via EU entities.

Conclusion

REACH SVHC and SCIP compliance are now core EU market access requirements, not optional disclosures. As enforcement and sustainability integration intensify through 2026, companies must adopt structured, data-driven chemical compliance strategies.

Organizations that proactively align with REACH and SCIP expectations will strengthen regulatory resilience, customer trust, and long-term EU market access.