EU Regulation (EC) No 1907/2006
REACH
Registration, Evaluation, Authorisation and Restriction of Chemicals
REACH is the European Union's comprehensive chemical regulation. It requires companies that manufacture, import, or sell articles in the EU to identify and manage risks from chemical substances. For product companies, the most immediate obligations involve substances of very high concern (SVHCs) on the Candidate List.
Full SVHC • Candidate List • Article 33 • SCIPClient Reporting
Compliance Dashboard
A snapshot of the live reporting dashboard our clients receive. Every engagement includes ongoing visibility into program status - supplier response rates, SVHC screening coverage, and Candidate List exposure - updated as the data moves.
Substance Coverage
0%
Parts with confirmed SVHC status against current Candidate List
SVHC Hit Rate
0%
Share of screened articles with at least one SVHC above 0.1% w/w
Supplier Response Rate
0%
Declarations received from active supply chain contacts
SCIP Dossiers Filed
0+
Candidate List SVHCs requiring ECHA notification as of latest update
Article 33 Status
0%
Downstream communications issued for confirmed SVHC-containing articles
Supplier Declaration Status
Substance Threshold Status
SVHC Screening Coverage by Product Line
Candidate List Growth (SVHCs over time)
Service Output
What You Receive
Complete, audit-ready REACH documentation packages including SVHC screening results, supplier data roll-ups, Article 33 communication templates, and compliance determination summaries.
Product-level SVHC Screening
Full screening of each article against the current ECHA Candidate List, with substance-level results documented by part or BOM line.
Supplier FMD Data Collection
Managed supplier outreach for Full Material Disclosure data, including validation, follow-up, and exception handling for non-responsive suppliers.
SCIP Dossier Preparation
End-to-end SCIP notification support, including dossier assembly, ECHA submission, and cross-reference against Waste Framework Directive obligations.
Audit-Ready Documentation
Compliance determination summaries, Article 33 communication templates, and packaged records formatted for customer audits and regulatory submissions.
Applicability
Who This Applies To
Any company placing articles on the EU market. If your products are sold in Europe, REACH applies to you. This includes:
- EU-based manufacturers producing articles that contain chemical substances above the relevant thresholds.
- Importers bringing products into the EU from outside the EEA, who assume the obligations of the EU producer.
- Companies further down the supply chain that must pass compliance data to their direct customers under Article 33.
- Distributors and brand owners selling finished goods under their own name in EU member states.
Regulatory Obligations
Key Requirements
SVHC Communication
Communicate the presence of SVHCs above 0.1% w/w to downstream recipients and, upon request, to consumers within 45 days.
ECHA Notification
Notify ECHA when an article contains an SVHC above 0.1% w/w and is produced or imported in quantities exceeding 1 tonne per year.
Database Submission
Submit information on articles containing SVHCs to ECHA's SCIP database, linked to the Waste Framework Directive obligations.
Substance Restrictions
Certain substances are restricted or outright banned in specific product categories. Compliance requires confirming absence or substitution.
Authorisation
Some SVHCs require explicit authorisation for continued use. Operating without authorisation while using a listed substance is a direct violation.
Critical Numbers
Key Thresholds
0.1%
Weight-by-weight (w/w) trigger for SVHC communication and ECHA notification obligations per article.
1 t/yr
Annual production or import volume threshold that activates ECHA Article 7(2) notification requirements.
2x/yr
Candidate List updates occur twice annually, typically in January and July. Programs must reassess at each update.
230+
SVHCs currently on the Candidate List and growing. Each addition can create new obligations for existing products.
Risk Areas
Common Compliance Gaps
- • Relying on company-level declarations instead of product-level or component-level data.
- • Failing to update compliance assessments when the Candidate List is revised twice per year.
- • Treating REACH as a one-time exercise rather than an ongoing, structured program obligation.
- • Missing SCIP notification requirements for complex articles with multiple sub-articles or assemblies.
- • Accepting supplier declarations at face value without validation or cross-referencing against FMD data.
- • Not tracking which specific substances are present and at what concentration across the BOM.
Our Approach
How The 3TGs Helps
We run the full process from supplier data collection through audit-ready documentation. No partial handoffs.
Product-level and BOM-level SVHC screening against the current Candidate List.
Supplier data collection campaigns for Full Material Disclosure (FMD) data.
SCIP dossier preparation and ECHA submission support.
Candidate List update impact assessments - twice per year, every year.
REACH compliance declarations and documentation packaging for customer submissions.
Gap analysis between current data and what customers or regulators require.
Ready to Run a Clean REACH Program?
We manage the full process from supplier data collection through audit-ready documentation. Fixed fees. No ambiguity on scope.
Start a Conversationinfo@3tgs.org · UK +44 20 3996 3623 · US +1 209 286 0756
London, W1B 3HH, United Kingdom

