REACH: substance restrictions for consumer products

# REACH: substance restrictions for consumer products

Regulation (EC) No 1907/2006 (REACH) governs chemicals in the EU, and for product sellers the sharp end is Annex XVII, which restricts the manufacturing, placing on the market and use of substances in articles such as textiles, leather, toys, jewellery and electronics. Articles containing a Candidate List substance of very high concern above 0.1% w/w trigger communication duties down the supply chain and to consumers on request.

Key facts

• REACH is Regulation (EC) No 1907/2006; its Annex XVII sets binding restrictions on substances in articles.
• An "article" is defined as an object which during production is given a special shape, surface or design that determines its function more than its chemical composition: in practice, your finished product and each of its components.
• If an article contains a substance of very high concern (SVHC) on the Candidate List above 0.1% weight by weight, suppliers must communicate this down the supply chain under Article 33, and consumers can request the information with a 45-day response deadline.
• The Candidate List is updated twice a year, so a compliant product can become non-compliant when a substance used in it is newly listed.
• Restriction entries relevant to consumer products include nickel release from metal parts in prolonged skin contact, certain phthalates in toys and childcare articles, azo dyes in textiles and leather, and chromium VI in leather.
• REACH enforcement is national: each member state designates inspectors who can demand your evidence.
• SCIP notification to ECHA is a separate duty for the same SVHC trigger; doing one does not satisfy the other.

1. REACH in one paragraph

Regulation (EC) No 1907/2006 governs chemicals in the EU. For product sellers, the sharp end is Annex XVII: restrictions on manufacturing, placing on the market and use of substances in articles, including limits relevant to textiles, leather, toys, jewellery and electronics. REACH also contains the Candidate List and authorisation regime, the Article 33 communication duty, and (for chemical manufacturers and importers) registration duties that sit upstream of product sellers. This guide focuses on what matters to companies placing finished products on the EU market: restrictions, SVHC communication, and the evidence inspectors expect.

2. Articles vs substances

An "article" means an object which during production is given a special shape, surface or design which determines its function to a greater degree than does its chemical composition. Your product is an article, and so is each component inside it: the zipper, the coating, the plastic housing. Restrictions apply to substances *in* articles, for example nickel release from metal parts in prolonged skin contact, or certain phthalates in childcare articles. The distinction matters because the 0.1% SVHC threshold is assessed per article, not per finished product: a complex product must be analysed article by article. Substances and mixtures as such (for example a bottle of glue sold as a chemical product) follow different REACH duties.

3. How Annex XVII restrictions work

Annex XVII lists substances with conditions on their manufacture, placing on the market or use. Each entry names the substance or group, the scope (which articles or uses are covered), and the limit or condition, such as a maximum concentration or a migration limit. Entries change: new restrictions are added and existing ones amended, so the consolidated Annex XVII on EUR-Lex is the only reliable reference. The table below shows entries that routinely affect consumer products; always confirm the current wording of each entry before relying on it.

Exemptions exist within individual entries, for example for certain product types or concentration thresholds, but they are narrow. Unless an entry expressly exempts your use, assume the restriction applies and verify in the legal text.

4. SVHC communication duties

If your article contains a substance of very high concern above 0.1% w/w, Article 33 requires you to provide the recipient of the article with sufficient information for safe use, at minimum the name of the substance. Recipients means professional customers down the supply chain, and the duty applies automatically on supply. Consumers can also request the information, and you must respond free of charge within 45 days. The Candidate List grows twice a year, so build a monitoring step into your compliance calendar: each update can create new communication duties for articles already on the market.

5. Candidate List monitoring in practice

Treat the Candidate List as a living input, not a one-off check. Assign an owner, subscribe to ECHA announcements, and re-screen your bill of materials against every update. For each newly listed substance, ask suppliers whether it is present in any article you place on the market above 0.1% w/w, and update your Article 33 communications and any SCIP notifications accordingly. Document each screening round with the list version and date: inspectors accept a dated, systematic process far more readily than ad-hoc assurances.

6. Testing strategy

Risk-based testing beats blanket testing: map materials, identify plausible restricted substances per material, and test accordingly with accredited labs. For example, test metal components for nickel release where prolonged skin contact occurs, plastics for restricted phthalates where they are used as plasticisers, and leather for chromium VI. Re-test when suppliers or materials change, because a component swap can silently break compliance. Keep supplier declarations as the first line of evidence and use testing to verify high-risk materials and new suppliers, not to replace supply-chain data entirely.

7. Documentation and enforcement

Keep supplier declarations, test reports and your restriction assessment in the technical file. REACH enforcement is national, and inspectors ask for evidence: which substances you assessed, against which Annex XVII entries and Candidate List version, what your suppliers declared, and what you tested. Non-compliance can lead to product withdrawals, recalls and penalties that differ by member state. If you sell in several member states, the strictest enforcement posture you face sets your practical standard.

Compliance checklist

• [ ] Map every material in your product to the Annex XVII entries that could apply.
• [ ] Screen your bill of materials against the current Candidate List, per article.
• [ ] Obtain SVHC and restricted-substance declarations from each supplier, in writing.
• [ ] Prepare Article 33 communications for any SVHC above 0.1% w/w, and a 45-day consumer-request process.
• [ ] File SCIP notifications where the same trigger applies.
• [ ] Set a review trigger for every Candidate List update and every Annex XVII amendment.
• [ ] Re-test high-risk materials when suppliers, formulations or processes change.
• [ ] Keep the full evidence file available for national inspectors.

What this means for businesses

For businesses, REACH turns chemical compliance into a supply-chain data discipline rather than a one-time test. The cost sits in supplier engagement, material mapping and continuous Candidate List monitoring, not in laboratory fees alone. Start with written declarations and full material disclosures from suppliers, because testing finished goods cannot practically cover every article in a complex product. However, note that REACH is an EU instrument: compliance here does not satisfy chemical duties in other markets, and restriction entries change, so this is a standing process with an owner and a calendar, not a project with an end date.

How the EU compares with other markets

The EU combines Annex XVII restrictions, the Article 33 communication duty and SCIP notification for SVHCs above 0.1% w/w. The United States has no equivalent article-level SVHC database; federal TSCA and state laws such as California Proposition 65 impose different duties with different triggers and warnings. The United Kingdom operates its own UK REACH regime with separate lists and timelines. Substance data collected for REACH can inform other regimes but does not satisfy them; assess each market separately.

Does REACH apply to importers as well as manufacturers?

Yes. Anyone placing articles on the EU market, including importers and distance sellers, carries the restriction and communication duties for the articles they supply.

What exactly counts as an "article"?

An object given a special shape, surface or design during production that determines its function more than its chemical composition. Each component of a complex product is assessed as an article in its own right.

How do I know whether my product contains an SVHC?

Ask suppliers for written declarations against the current Candidate List, per article and with concentration data, and verify high-risk materials with accredited testing. Declarations first, testing targeted by risk.

What happens if I miss a Candidate List update?

A newly listed substance present in your articles above 0.1% w/w creates new Article 33 and SCIP duties from the listing. Dated, systematic re-screening is your defence; ad-hoc checks are not.

Is laboratory testing of every product required?

No. REACH expects a risk-based approach: supplier declarations and material assessment as the foundation, accredited testing where the risk warrants it, and re-testing when materials or suppliers change.

Assumptions and limitations

• This guide covers Annex XVII restrictions and the Article 33 communication duty for articles; it does not cover REACH registration, evaluation or authorisation of substances as such.
• Concentration thresholds are assessed per article; verify entry wording in the consolidated Annex XVII.
• Restriction entries and the Candidate List change; always verify against the current official texts.

Official sources

• REACH Regulation (EC) No 1907/2006 on EUR-Lex
• Waste Framework Directive (EU) 2008/98/EC on EUR-Lex, the SCIP legal basis

Last verified: 2026-09-29.

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