REACH Compliance | The 3TGs

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 • SCIP

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)

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.

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:

  1. EU-based manufacturers producing articles that contain chemical substances above the relevant thresholds.
  2. Importers bringing products into the EU from outside the EEA, who assume the obligations of the EU producer.
  3. Companies further down the supply chain that must pass compliance data to their direct customers under Article 33.
  4. Distributors and brand owners selling finished goods under their own name in EU member states.

Key Requirements

Article 33

SVHC Communication

Communicate the presence of SVHCs above 0.1% w/w to downstream recipients and, upon request, to consumers within 45 days.

Article 7(2)

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.

SCIP

Database Submission

Submit information on articles containing SVHCs to ECHA's SCIP database, linked to the Waste Framework Directive obligations.

Annex XVII

Substance Restrictions

Certain substances are restricted or outright banned in specific product categories. Compliance requires confirming absence or substitution.

Annex XIV

Authorisation

Some SVHCs require explicit authorisation for continued use. Operating without authorisation while using a listed substance is a direct violation.

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.

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.

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.

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info@3tgs.org  ·  UK +44 20 3996 3623  ·  US +1 209 286 0756

UK Office +44 20 3996 3623
US Line +1 209 286 0756
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London, W1B 3HH, United Kingdom