[Home](/)/[Resources](/resources)/EU REACH SVHC for Electronics EUChemicals # EU REACH SVHC for Electronics: Article 33 Communication and SCIP Database Obligations REACH's SVHC obligations are easy to overlook when you're focused on CE marking, but they carry their own enforcement risks and supply chain implications. The Candidate List keeps growing, and every update is a potential new obligation for products already on the market. Here's how to stay on top of it. Copy Link[Share on WhatsApp](https://wa.me/?text=https%3A%2F%2Fkrono-labs.com%2Fguides%2Feu-reach-svhc-electronics) At a glance Regulation REACH (EC) 1907/2006 Threshold 0.1% w/w per article SCIP database ECHA Article 33 45-day notification obligation ## Key REACH SVHC obligations for electronics ### Substances of Very High Concern (SVHCs) ECHA publishes a Candidate List of SVHCs that currently contains over 240 substances. The list includes carcinogenic, mutagenic, or reprotoxic (CMR) substances, persistent bioaccumulative and toxic (PBT) substances, very persistent and very bioaccumulative (vPvB) substances, and endocrine disruptors. The Candidate List is updated twice per year — typically in January and July — and each update can add substances that previously had no notification obligation. ### Article 33 notification obligation Suppliers of articles containing any SVHC above a concentration of 0.1% w/w must notify their business customers with sufficient information to allow safe use of the article — including the substance name, its location in the article, and guidance for safe handling or disposal. Consumers can submit a request for the same information and must receive a response within 45 days. ### SCIP database requirement Since January 2021, producers and importers of articles containing SVHCs above 0.1% w/w are required to submit information to ECHA's SCIP database before placing the product on the EU market. SCIP information must cover the substance identity, the article category, safe use instructions, and information to support waste management. This obligation applies to articles that contain SVHCs as part of complex objects — a finished PCB assembly, for example — not just to raw materials. ### Electronics-specific SVHCs Common SVHC substances found in electronics hardware include certain flame retardants such as HBCDD and specific PBDEs, phthalate plasticisers (DEHP, BBP, DBP, DIBP) used in cable insulation and enclosures, bisphenol A in epoxy-based laminates and encapsulants, and lead compounds in certain solder alloys not covered by RoHS exemptions. Connectors, capacitors, and batteries are common locations for SVHC-containing materials. ## How to manage REACH SVHC compliance 01 Screen your product's materials and components against the current ECHA Candidate List — request a Declaration of Conformity and SVHC content data from each tier-1 supplier, specifying the substance name, CAS number, and weight fraction for any listed substance present above 0.1%. 02 Calculate the SVHC concentration per article as a whole — the 0.1% threshold applies at the article level; a substance present at 1% in a small sub-component may or may not exceed 0.1% of the overall article depending on the relative weights involved. 03 If SVHCs are confirmed above 0.1% w/w: prepare Article 33 notification content including the substance name, CAS number, location in the article, and safe use or disposal guidance; this information must be communicated to every business customer receiving the article. 04 Register your article in the ECHA SCIP database before the first EU shipment — create a company account on ECHA's REACH-IT submission portal, prepare the SCIP notification using the required data elements (article characterisation, SVHC identity, safe use instructions), and submit prior to placing the product on the EU market. 05 Monitor the ECHA Candidate List for updates (published typically in January and July each year) and re-assess your product for any newly listed substances that may push previously borderline articles over the 0.1% threshold requiring notification. ## Frequently asked questions ### Does REACH Article 33 apply to electronics imported into the EU? Yes. Any company that imports finished electronics articles into the EU is treated as the 'producer' of those articles under REACH for the purposes of the Article 33 and SCIP obligations. This means EU importers of electronics manufactured outside the EU bear full responsibility for SVHC notification and SCIP registration, regardless of whether the non-EU manufacturer has performed any assessments. ### What is the SCIP database and who must submit to it? SCIP is the database for information on Substances of Concern in articles as such or in complex objects (Products) established by ECHA under the Waste Framework Directive. Any producer or importer of articles that contain SVHCs above 0.1% w/w must submit a SCIP notification before placing the article on the EU market. The database is public and designed to support waste managers in identifying hazardous substances during end-of-life processing. ### How is the 0.1% SVHC threshold calculated for electronics assemblies? The threshold is calculated as a weight fraction of the SVHC relative to the weight of the entire article. For a complex product like a finished electronic device, the article is the complete assembled product unless the sub-components qualify as separate articles that are intentionally separable. ECHA guidance suggests that where components are individually removable and serve distinct functions, they may be assessed as separate articles — but this is not always straightforward in practice and should be documented carefully. ### What is the difference between REACH SVHC notification and RoHS compliance? RoHS restricts specific substances (lead, mercury, cadmium, hexavalent chromium, PBBs, PBDEs, DEHP, BBP, DBP, DIBP) in electrical and electronic equipment to defined maximum concentration values. REACH SVHC notification is a transparency obligation — it does not restrict use but requires disclosure. A product can be both RoHS-compliant and subject to REACH Article 33 notification for a different SVHC substance not covered by RoHS. Both obligations must be managed independently. **Disclaimer:** Educational resource only. Regulatory requirements change and vary by product category. Consult an accredited test laboratory or qualified compliance engineer before making certification decisions. 🇪🇺 CE Marking roadmap for your product Every standard, document, and test that applies — free, no account required. See your free roadmap[ Want an expert to take your product through 🇪🇺 CE Marking compliance for you? One consultant from Krono's compliance team takes your product from requirements to legal sale, with a fixed quote before any work starts. See compliance services](/services) Learn this properly In-depth course that teaches the full process, not just this one answer. [Start the course — $149](/courses/06-rohs-reach-compliance-complete-guide)[Prefer to read? 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