Supplier REACH compliance: the guide to securing your articles and your evidence

In brief

• Supplier REACH compliance is not about "collecting SDSs". It is about demonstrating, article by article, which Candidate List substances are present above 0.1% w/w, and then passing the information on to the right recipient.
• Four obligations apply cumulatively and do not replace one another: registration of substances above 1 t/year, information down the supply chain (Article 33), notification to ECHA (Article 7(2)), and SCIP notification.
• The Candidate List has had 253 entries since 4 February 2026 and is revised twice a year: each revision can bring an article already on the market within the scope of the obligations.
• The 0.1% w/w threshold is assessed per article, never on the total mass of an assembly. This is the most common calculation error found in audits.
• In France, the AGEC law (Article L. 541-9-1 of the Environmental Code) adds a consumer information requirement which is distinct from both SCIP and Article 33.
• This guide provides two decision tables (responsibilities, evidence), a worked calculation example, a 12-point audit checklist and the 6 most common mistakes.

1. Supplier REACH compliance: what the regulation actually requires

A supplier's REACH compliance consists in demonstrating three things: that the substances contained in what it places on the market are known, that their use is authorised under the intended conditions, and that the information flows through to the recipient. Regulation (EC) No 1907/2006 is directly applicable in France: it requires no transposition and applies to any company in the European Economic Area that manufactures, imports, distributes or uses substances, on their own, in mixtures or in articles (consolidated text on EUR-Lex, overview by the French Ministry for the Ecological Transition).

Three notions must be distinguished before looking at the obligations, as they underpin everything else:

• The substance: a chemical substance, on its own or in a mixture.
• The mixture: a preparation of two or more substances (paint, degreaser, adhesive, lubricant).
• The article: an object which, during production, is given a special shape, surface or design which determines its function to a greater degree than its chemical composition (Article 3(3)).

This last definition is decisive for a manufacturing plant. A seal, a screw, a cable, an enclosure or a circuit board are all articles. A complete assembly is also an article, but it contains other articles: the regulation then requires reasoning at each level, because it is the "article" level that triggers the 0.1% w/w threshold. Packaging is also an article: for substances of concern in packaging (PPWR, PFAS), a specific framework applies in addition to REACH.

An operational principle: "once an article, always an article"

An article remains an article, even when it is incorporated into a more complex object. This interpretation, confirmed by the Court of Justice of the EU (judgment of 10 September 2015, Case C-106/14, FCD and FMB) against the interpretation previously adopted by the Commission and ECHA, whose guidance has since been updated accordingly, has a very concrete consequence: responsibility cannot be "diluted" through assembly. If a component exceeds 0.1% w/w of a substance of very high concern (SVHC), the final assembly carries that information, even if the concentration relative to the total mass becomes negligible.

What compliance is not

Three common misconceptions are costly:

1. REACH compliance is not a certification. No ISO 9001, ISO 14001 or IATF certificate constitutes proof of REACH compliance.
2. It is not a permanent status. A supplier declaration from 2023 says nothing about substances added to the Candidate List in 2025.
3. It is not a single document. It is a body of evidence, dated and versioned, by article and by substance.

2. Who is responsible for what in the supply chain?

The allocation of REACH responsibilities does not follow commercial position but legal position: manufacturer, importer, downstream user, distributor. A single industrial site can hold several roles depending on the flows - and therefore accumulate obligations. The table below serves as a basis for discussion in a compliance review.

Two points that audits regularly bring to light:

• The importer cannot hide behind its supplier. The obligations under Article 33, Article 7(2) and SCIP fall on whoever places the article on the Union market. An untranslated, undated Chinese declaration is not evidence.
• A distributor that reformulates or applies its own brand changes status. The boundary between trading and placing on the market "under its own responsibility" should be settled with the legal department, as it shifts the obligations.

3. REACH obligations affecting suppliers of articles

The following table summarises the applicable obligations, with their exact trigger. It serves as a shared reference between Purchasing, Quality, Regulatory and HSE.

Three useful readings of this table:

• The 1 t/year threshold only concerns registration and Article 7(2). Article 33 and SCIP apply from 0.1% w/w, regardless of tonnage. A product sold at 20 units a year is still concerned.
• The SDS and Article 33 do not cover the same objects. The SDS concerns substances and mixtures; Article 33 information concerns articles. Waiting for an SDS for an article means waiting for a document that does not exist.
• Each obligation has its own recipient. A professional customer, a consumer, ECHA and the French consumer under AGEC do not receive the same information, at the same time, through the same channel.

4. SVHC Candidate List: 253 substances since 4 February 2026, revised twice a year

The Candidate List identifies substances that may become subject to authorisation. It has had 253 entries since 4 February 2026, the date on which new substances were added (source: French national REACH regulatory helpdesk, INERIS). It is updated twice a year by ECHA, which makes it a living reference rather than a fixed reference document (official Candidate List).

A substance may be included if it meets at least one criterion:

• carcinogenic, mutagenic or toxic for reproduction, category 1A or 1B;
• persistent, bioaccumulative and toxic (PBT);
• very persistent and very bioaccumulative (vPvB);
• equivalent level of concern, in particular endocrine disruptors, respiratory sensitisers, or persistent, mobile and toxic substances (PMT / vPvM).

What "253 entries" means in practice

The count is made in entries, and an entry may group several substances or forms (salts, isomers). Practical consequence: you do not compare a number of substances with a number of rows in a spreadsheet; you compare identifiers. The right identifiers are the CAS number, the EC number and, where there is ambiguity, the name of the entry as it appears on the list.

The three dates to track in a document management system

Without these three dates, a REACH dossier is hard to defend: you can prove that you collected documents, but not that you were up to date.

A direct consequence for purchasing

Each twice-yearly revision can bring in a substance that is already present in your articles. Two reflexes limit the exposure:

1. Ask suppliers about substances under evaluation, not only about those already listed, in order to anticipate a substitution or a new declaration.
2. Include a contractual notification clause: the supplier undertakes to report any change in formulation and any new inclusion concerning its articles, within a defined period.

5. Annex XIV and Annex XVII: authorisation, restriction, and what this changes for your purchasing

Annexes XIV and XVII are often confused with the Candidate List. Yet they have neither the same function nor the same operational consequences.

Annex XIV: anticipate the sunset date rather than be caught out by it

An Annex XIV substance may continue to be used until its sunset date. After that date, use in Europe requires an authorisation granted by the European Commission, following the opinion of ECHA's scientific committees. For a buyer, the challenge is to have a substitution plan in place before that deadline: qualification of an alternative, trials, customer validation. Discovering the deadline during an audit is a costly scenario, as it can halt a production line.

Annex XVII: a restriction is read "use by use"

A restriction does not always mean a general ban. It may set a maximum concentration for certain uses, or target only articles intended for the general public. Two consequences:

• Compliance is assessed for a given use, not for the substance in general.
• The evidence expected is often analytical: a declaration of compliance with no method or limit of detection is weak in an audit.

A substance may fall under several reference lists at the same time (for example, being on the Candidate List and then being included in Annex XIV or XVII). Monitoring must therefore be by substance and by reference list, never by a single list.

6. SDS and eSDS: reading Annex II and exposure scenarios correctly

The safety data sheet (SDS) is the information vehicle for substances and mixtures. Its content and format are governed byAnnex II of the REACH Regulation: 16 sections, in a defined order. The SDS is mandatory for hazardous substances and mixtures, as well as for substances of very high concern (overview by the Ministry).

The five checks that are enough to rule out 80% of problematic SDSs

1. The revision date and version. An SDS more than three years old without a justified revision should be questioned, particularly if the classification of the substance has changed.
2. Section 1.2 (relevant identified uses). If your industrial use is not listed, your supplier has not assessed it: this is a gap, not a detail.
3. Section 3 (composition). It may declare substances above generic thresholds without being exhaustive. An SDS is not a certificate of full composition.
4. Consistency of classification / labelling / limit values. A classification that is inconsistent with the rest of the document often signals a hastily assembled document.
5. Language and destination. An SDS supplied in English to a French user does not, in itself, meet the requirement to provide it in the recipient's language.

eSDS: when the SDS is extended with exposure scenarios

Where the substance is subject to a chemical safety assessment - in particular above 10 t/year for hazardous or PBT/vPvB substances - the SDS is supplemented with exposure scenarios in an annex. It is then referred to as an extended safety data sheet, or eSDS. An exposure scenario describes the conditions under which the substance can be used safely: process, quantity, duration, temperature, ventilation, personal protection, waste management.

For the downstream user, the logic is as follows:

• check that each actual use on the site is covered by a scenario;
• if a use is not covered, inform the supplier so that it can complete its assessment, or carry out your own chemical safety assessment;
• keep evidence of this check, dated, by use and by SDS.

This is a classic audit finding: the eSDS is on file, but nobody can say whether the actual use on the site - temperature, flow rate, containment - matches the scenario described. An SDS received is not an SDS applied.

For further guidance on reading scenarios, the Ministry publishes a dedicated guide: All about exposure scenarios. ECHA also provides resources on extended SDSs.

7. Which document proves what? Table of evidence and its limitations

No single document proves the REACH compliance of an article on its own. The robustness of a dossier comes from the layering of different types of evidence, each covering what the others do not.

How to read this table in practice

• An SVHC declaration without a list version says little: "no SVHCs" against which list, as of which date?
• An SCIP notification attests to a notification, not to the quality of the composition analysis.
• An ISO certificate proves an organisation, not a substance.
• A test report proves a measurement, not an absence.

The right reflex: cross-check at least two independent sources for each critical article. A supplier declaration plus a test report, or a SCIP notification plus an internal calculation sheet, are worth more than three declarations of the same kind.

8. Calculating the 0.1% w/w threshold per article: method and worked example on an industrial assembly

The 0.1% threshold is assessed on the basis of the mass of substance relative to the mass of the article, not the mass of the finished product. It is a mass/mass ratio (w/w), often written% w/w. The method has four steps.

Step 1 - Break the product down into articles

Each article must be identified within the meaning of Article 3(3): an object whose shape, surface or design determines its function. An industrial assembly generally contains several articles, and sometimes sub-articles. This breakdown must be written down and justified: it is the first document the auditor will ask for.

Step 2 - Weigh each article

The reference mass is that of the article, not that of the product delivered. A 12 g screw, a 150 g seal, a 1,200 g cable harness.

Step 3 - Calculate the mass of substance

Mass of substance = mass of the article × concentration of the substance in the article.

Two common pitfalls: the concentration must be the concentration in the article, not in the raw material purchased (a coloured sheath may contain an additive present only in the masterbatch); and units must be converted rigorously (g, mg, kg).

Step 4 - Compare with the threshold

Threshold (by mass) = mass of the article × 0.1%. If the mass of substance exceeds this threshold, the article is above 0.1% w/w: the obligations under Article 33, SCIP and, where applicable, Article 7(2) apply for that substance. The detailed calculation sheet and borderline cases are presented in our method to calculate the concentration per article.

Full worked example: UC-40 industrial control unit

Take an industrial assembly of 12,400 g, produced at 4,000 units per year, made up of 8 articles. The supplier of a seal has declared DEHP (bis(2-ethylhexyl) phthalate); the fastener supplier has declared lead in a brass insert.

Four lessons from this calculation.

1. The complete product appears flawless. The total quantity of DEHP in the unit is 1.44 + 0.27 + 0.40 = 2.11 g, i.e. 0.017% of the total mass of 12,400 g. Calculated on the finished product, the dossier would conclude that there is no exceedance. Yet this is wrong: two articles exceed 0.1% w/w.
2. The threshold is decided on small masses. The 150 g seal contains 0.27 g of DEHP, i.e. 0.18%: above the threshold, although it represents 1.2% of the mass of the assembly. The lighter the article, the smaller the quantity of substance needed to cross the threshold.
3. The breakdown changes the result. The 95 g brass insert contains 0.285 g of lead, i.e. 0.30% - above the threshold. Relative to the 300 g "fasteners" article, the same lead represents 0.095%, below the threshold. Two readings, two conclusions: hence the importance of documenting the breakdown adopted, with a diagram and a justification.
4. A supplier declaration is not an analysis. Had the seal supplier stated "SVHC-free", the gap would never have been detected. This is why critical articles justify independent verification.

What this example triggers, obligation by obligation

• Article 33(1): the supplier of the assembly must inform its professional recipients of the presence of DEHP above 0.1% w/w in the cable harness and in the seal, with at least the name of the substance and the information allowing safe use.
• Article 33(2): a consumer who requests it must receive this information free of charge, within 45 days.
• Article 7(2): the annual quantity of DEHP contained in the articles produced is 2.11 g × 4,000 = 8.44 kg/year, well below 1 t/year. No notification to ECHA is therefore required for this substance. It would take around 118,500 units per year to reach the one-tonne threshold.
• SCIP: notification remains mandatory, with no tonnage condition, for the two articles concerned.
• AGEC: if the product falls within the scope of the waste-generating products covered by Article L. 541-9-1 of the Environmental Code, specific consumer information must be provided.

This last point is essential: the 1 t/year threshold only applies to Article 7(2). It does not exempt from Article 33, SCIP or AGEC. A company that "falls below one tonne" still owes the information.

Borderline cases to document

• Mixture incorporated into an article: the concentration to use is that of the substance in the article, not that of the mixture before processing.
• Chemical reaction during manufacture: a substance consumed by reaction is no longer "contained" in the article; this must be demonstrated, not assumed.
• Alloys and impurities: an element present as an impurity at a significant level must be monitored, even if it is not intentional.
• Reuse of a component already placed on the market: the information received must be retained and passed on downstream.

The calculation methodology and examples of borderline cases are detailed in the official guidance, in particular the guide for suppliers of articles published by the national regulatory helpdesk.

9. SCIP and the French AGEC obligation: two obligations distinct from Article 33

Three information obligations coexist in France, with different legal bases, recipients and deadlines. Treating them as a single mechanism is a classic source of non-compliance. To prepare a SCIP dossier from supplier data, the five-step method is detailed in a dedicated guide.

SCIP: one notification per article concerned

The SCIP database (Substances of Concern In articles as such or in complex objects (Products)) has been operational since 5 January 2021. It has no tonnage threshold: as soon as an article contains an SVHC above 0.1% w/w, it must be notified. For a complex object, the notification covers the articles concerned, with their identification.

Three misconceptions to correct:

1. "SCIP is proof of REACH compliance": no. SCIP only covers information on SVHCs.
2. "SCIP replaces Article 33": no. The professional customer must receive the information directly, in writing.
3. "SCIP replaces AGEC": no. The criteria and scope of AGEC are distinct, as the official FAQ on Article 13-I of the AGEC law.

AGEC: consumer information, not a technical register

Article L. 541-9-1 of the Environmental Code requires consumers to be informed of the environmental qualities and characteristics of waste-generating products, in particular the presence of hazardous substances. Since 1 January 2023, this information must be available, in particular in digital form, at the time of purchase (mandatory environmental information, French Ministry for the Ecological Transition).

Two points of method:

• The information threshold is set at 0.1% by mass, consistent with REACH, but the product scope and the statements are specific to French law (statement "contient une substance dangereuse" [contains a hazardous substance] or "contient une substance extrêmement préoccupante" [contains a substance of very high concern]).
• The information obligations are deferred by six months after the substance is first identified as hazardous. This period must be built into procedures, or the information will be provided too late.

Consequence for an exporting or multi-customer plant: the same article may require three different deliverables - Article 33 information to the industrial customer, a SCIP dossier, and an AGEC statement on the product sheet intended for the French market.

10. Collecting and securing supplier evidence: the 6-step process

The operational difficulty is not understanding the regulation, but obtaining reliable data, year after year, from a heterogeneous supplier portfolio. A six-step process, with explicit responsibilities, avoids improvised collection campaigns. This logic of dated, versioned evidence underpins all regulatory supplier traceability.

Step 1 - Map the articles placed on the market

Build an article database: reference, description, mass, known composition, supplier, import status, destination markets. Without mass, the 0.1% calculation is impossible; without import status, responsibility is wrongly allocated.

Step 2 - Set the reference version of the Candidate List

Each campaign must be based on a dated version of the list (for example: "253 entries, version of 4 February 2026"). Supplier responses are then linked to this version, which makes it possible to know what needs to be followed up at the next revision.

Step 3 - Use a structured questionnaire, not a free-form email

A usable questionnaire asks, for each article concerned, for:

• the identification of the article and its mass;
• the name of the substance, its CAS number and its EC number;
• the concentration in% w/w in the article, and the mass of substance;
• the version of the Candidate List used;
• the date, name and position of the signatory;
• the commitment to notify any change in formulation.

Step 4 - Follow up according to a written rule

A 100% response rate on the first send does not exist. Plan two reminders at fixed intervals, an alternative channel (technical contact, not just sales), and a documented contractual consequence for non-responses.

Step 5 - Cross-check sources

For each critical article, compare the declaration, the available SDS, the SCIP dossier and the internal calculation. An inconsistency between the declared mass and the mass received, or between an "SVHC-free" declaration and an SDS mentioning a listed substance, must be treated as an alert, not as an administrative glitch.

Step 6 - Archive, version, schedule

Retain the evidence with its date of receipt, in a single location, and schedule a review at each update of the Candidate List and of Annexes XIV and XVII, and at each change of supplier or formulation.