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# REACH Regulation and CE Marking: What Hardware Makers Need to Know

REACH (EC 1907/2006) is the EU chemicals regulation that runs alongside CE marking directives. For hardware companies, the main touchpoints are SVHCs in articles, the SCIP database notification obligation, and the requirement to communicate substance information down the supply chain.

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## The REACH framework for articles

REACH distinguishes between substances, mixtures, and articles. Hardware products — PCBs, enclosures, cables, connectors — are articles under REACH. The main obligation for article producers and importers is around Substances of Very High Concern (SVHCs) listed on the Candidate List.

SVHCs are added to the Candidate List periodically by ECHA. The list is updated twice a year and has grown significantly since REACH entered into force. You need to check your product against the current Candidate List, not just a static reference from when the product was designed.

## SVHC obligations by threshold

Above 0.1% w/w in article

Notify ECHA via the SCIP database (mandatory for all producers and importers of articles containing SVHCs above 0.1%). This applies even if the SVHC use is not restricted.

Above 0.1% w/w in article + B2C supply

Provide information to consumers on request (Article 33). You must respond within 45 days to any consumer who asks whether the article contains an SVHC and how to use it safely.

Above 0.1% w/w + supplied to professional users

Proactively provide sufficient information to allow safe use of the article, including the SVHC name, at minimum.

## SVHCs commonly found in electronics hardware

Lead and lead compounds

Solder alloys (if not using RoHS-compliant lead-free solder), PVC stabilisers

Cadmium and cadmium compounds

Semiconductor contacts, certain pigments in plastics

Bisphenol A (BPA)

Polycarbonate enclosures, epoxy resins used in PCB substrates and adhesives

DEHP and other phthalates

PVC cable insulation, flexible enclosure materials

Diboron trioxide

Certain flame retardant formulations in plastics

Short-chain chlorinated paraffins (SCCP)

Some PVC stabilisers and rubber cable materials

This list is illustrative, not exhaustive. Check the current ECHA Candidate List for all SVHCs.

## Frequently asked questions

### Does REACH require a CE mark?

No. REACH is a chemicals regulation — it operates independently of CE marking directives. There is no CE mark associated with REACH compliance. However, REACH obligations still apply to hardware products that are CE marked under other directives.

### How is REACH different from RoHS for hardware?

RoHS restricts specific substances at specific concentration limits in EEE — if you are above the limit, you are non-compliant. REACH operates differently: it requires you to communicate about SVHCs above threshold but does not necessarily prohibit the substance (unless it appears on the Authorisation List or Restriction List). RoHS exemptions exist; REACH has its own authorisation and restriction framework.

### What is the SCIP database and do I need to use it?

SCIP (Substances of Concern In articles as such or in complex objects) is ECHA's database. EU producers and importers of articles containing SVHCs above 0.1% w/w must submit information to SCIP. This has applied since January 2021. Non-EU companies placing articles on the EU market through an EU importer — the importer holds the SCIP notification obligation.

### How do I get REACH data from my supply chain?

Request REACH SVHC declarations from your component and material suppliers. Many use IPC-1752A Material Declaration or the ECHA SCIP format. Focus especially on plastics, rubber compounds, cable materials, and any articles that use surface treatments or specialty coatings.

**Disclaimer:** Educational resource only. Not legal advice. The ECHA Candidate List is updated regularly. Always check the current list and ECHA guidance before making compliance declarations.

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