REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals)

The name describes its own structure. Registration: manufacturers and importers of a chemical substance above one tonne per year must file a technical dossier with ECHA covering its properties and safe use. Evaluation: ECHA and member-state authorities review dossiers and can request further testing. Authorisation: substances placed on Annex XIV — the highest-risk tier — cannot be used past a "sunset date" without a specific, substance-by-substance authorization. Restriction: Annex XVII bans or caps specific uses of a substance outright, independent of whether it's classified as an SVHC at all.

Most product-data teams never touch registration or authorization directly — those are chemical-producer obligations. The field that reaches a catalog is the Candidate List, one tier below Annex XIV.

A Substance of Very High Concern is a chemical ECHA has formally identified under Article 57 criteria — carcinogenic, mutagenic, toxic for reproduction, persistent/bioaccumulative/toxic, or of equivalent concern such as endocrine-disrupting properties. ECHA adds to the Candidate List roughly twice a year; it has grown from an initial 2008 publication to well over 200 entries.

Article 33 sets the disclosure trigger: if an SVHC is present above 0.1% weight-by-weight in an article, the supplier must provide the recipient enough information for safe use — at minimum, the substance's name — and must do so within 45 days of a request at no charge. Being on the Candidate List does not make a substance illegal to use; it makes disclosure mandatory once that concentration is crossed.

Since January 2021, under the EU Waste Framework Directive, any company placing an article containing an SVHC at or above 0.1% w/w on the EU/EEA market must also submit a SCIP dossier (Substances of Concern In Products) to ECHA — separate from, and more detailed than, the Article 33 disclosure. SCIP asks for information Article 33 doesn't: where in the product the substance is located, what material it's part of, and safe-use and end-of-life handling instructions.

Article 33 is a disclosure duty toward your customer; SCIP is a filing duty toward ECHA. A company can owe both, on the same product, for the same substance, and the two aren't satisfied by the same document.

All three restrict chemicals in commerce, at very different scope.

Rule	Substance scope	Product scope	Jurisdiction
REACH	Any SVHC, plus registered chemicals broadly	Virtually any article	EU/EEA
RoHS	Ten named substances	Electrical/electronic equipment only	EU
Prop 65	1,000+ listed chemicals	Any product sold into California	California, but binds any seller shipping there

For product data, REACH/SVHC status is a composition-driven attribute — usually tracked at the bill-of-materials or component level rather than assigned once per finished SKU, since the same finished product can source a component from different suppliers whose materials differ. It is a distinct field from RoHS declaration and distinct from SDS content, which governs substances and mixtures sold as such rather than substances present inside a manufactured article.