REACH compliance: from document collection to evidence, article by article.

In brief

• Support for REACH compliance covers five documentary objects: articles and their breakdown, Candidate List substances (SVHC), SDS and eSDS, SCIP notifications, and the supplier evidence that underpins them all.
• It is intended for manufacturers who must demonstrate, article by article, that no SVHC exceeds 0.1% w/w - or that the required information has been passed on to the right recipient.
• The engagement runs in four phases: scoping and perimeter, supplier collection, verification and qualification, ongoing management. Each phase has its deliverables.
• Tracklab is neither an ERP, nor a production tool, nor a regulatory monitoring tool: it is a platform that centralises supplier and product data, automates document collection and extracts critical data from it.
• A REACH certificate does not exist as an official instrument: what you receive is a declaration or a REACH statement, whose value depends entirely on what it contains.

What REACH compliance support covers

Regulation (EC) No 1907/2006 is directly applicable in France: it is not transposed, it applies (consolidated text on EUR-Lex, presentation by the French Ministry for Ecological Transition). Four obligations add up without replacing one another: information in the supply chain (Article 33), notification to ECHA (Article 7(2)), the SCIP notification and compliance with Annexes XIV and XVII.

The support covers the documentary scope that makes it possible to meet these obligations, and then to prove it.

Articles and their breakdown

The 0.1% weight by weight (w/w) threshold is assessed per article, within the meaning of Article 3(3), and not on the mass of the finished product. An industrial assembly itself contains articles: seals, fasteners, cables, boards. The engagement therefore begins with a written, justified breakdown, with the mass of each article. This is the first document the auditor asks for.

SVHC and the 0.1% w/w threshold

The Candidate List has had 253 entries since 4 February 2026 and is revised twice a year (official ECHA list, INERIS summary). Each collection campaign is linked to a dated version of this list, with reliable identifiers: CAS number, EC number, entry name. A "no SVHC" declaration without a list version proves nothing.

SDS and eSDS

The safety data sheet (SDS) is governed byAnnex II ; the extended SDS (eSDS) adds exposure scenarios. The support checks the version, section 3 (composition), section 1.2 (identified uses) and the actual coverage of your conditions of use.

Article 7(2) and SCIP notification

Notification to ECHA requires two cumulative conditions: SVHC above 0.1% w/w and more than one tonne per year of that substance in the articles produced or imported. SCIP, by contrast, applies with no tonnage threshold, before placing on the market (SCIP database). The two procedures are handled separately, each with its own evidence.

Supplier evidence

Structured statements, SDS, SCIP dossiers, analysis reports, written exchanges: the value of a file comes from cross-checking independent sources, and from their dating.

Frameworks covered

The four situations that trigger a REACH project

A customer audit or supplier qualification

A customer asks for your REACH file at short notice. The need is not to "produce documents", but to retrieve, by item reference, the evidence and its date.

Placing a new item on the market

New component, new supplier, new country of import: the article breakdown and composition data must be in place before the first delivery, not after.

A revision of the Candidate List

Two revisions a year can move an article already on the market into scope of obligations. The operational question is simple: which items must be re-queried, and with which suppliers?

A request from an ordering customer or an end customer

Supplier questionnaire, statement request, SCIP notification requirement, a consumer request under Article 33(2): the response must be accurate, sourced and traceable.

The four-phase engagement

Phase 1 - Scoping and article perimeter

Launch workshop with the Quality, Purchasing and Regulatory teams. The scope is set: product families, destination markets, import status, supplier criticality.

Deliverables : scoping note, article tree with masses, list of suppliers to contact, reference version of the Candidate List.

Phase 2 - Supplier document collection

Structured campaign: questionnaire by supplier type (articles, substances and mixtures), reminders at fixed intervals, technical channel in addition to the commercial contact. Each document received is linked to the article concerned. The method follows the principles of a regulatory document management method.

Deliverables : collection matrix, progress status per supplier, centralised and time-stamped document library.

Phase 3 - Verification and qualification

Consistency check: declared mass, concentration in the article, list version, consistency between statement and available SDS, consistency between SCIP dossier and internal data. Gaps are qualified and prioritised by criticality.

Deliverables : gap report, 0.1% w/w calculation sheets per article, action plan with owners.

Phase 4 - Ongoing management and evidence

The framework becomes a process: reviews scheduled at each revision of the Candidate List and the annexes, deadline alerts, updates when a supplier or formulation changes.

Deliverables : deadline dashboard, review calendar, consolidated audit file.

Concrete deliverables

• Article / SVHC register : one line per article, with mass, identified substances, concentration, calculated threshold and evidence status.
• Evidence matrix : for each critical article, the available documents, their date, their source and their level of reliability.
• Deadline dashboard : Candidate List revisions, SDS validity, statement renewals, pending consumer requests.
• Audit file : ordered selection of evidence, with the version of the framework used, exportable for a customer or an authority.

What Tracklab is not - and why it matters when choosing a tool

Tracklab is neither an ERP, nor a production or inventory management tool, nor a regulatory monitoring tool. This positioning is not a marketing nuance: it determines what you can expect from the tool.

• An ERP describes flows, inventory and costs. It does not read a 90-page SDS, does not extract a CAS number and does not link a statement to an article.
• A production tool manages manufacturing orders. Documentary compliance is not its purpose.
• Regulatory monitoring remains the role of official sources: ECHA, the ministry, the national REACH helpdesk. Tracklab does not interpret the regulation for you; the platform structures and leverages the data your suppliers send you.

What the platform does: centralise supplier and product data, automate document collection, link each document to the article concerned, extract with AI the critical data it contains (mass, identifiers, concentration, dates, versions), track deadlines and keep an enforceable history.

Choosing REACH software therefore comes down to settling a precise question: does the tool work on the documents, or only on fields entered by hand? A manually fed "compliance" module reproduces the problem it claims to solve.

REACH certificate, statement, declaration: what each document proves

No official REACH certificate is issued by ECHA or by the European Commission. The documents you receive fall into three distinct families, and it is this distinction that determines their value in an audit.

Three reflexes follow: request a structured REACH statement rather than a generic document; refuse a system certificate as REACH evidence; cross-check at least two independent sources for each critical article.

Which sectors

• Food : packaging, equipment, food-contact materials, which are also subject to their own framework (Regulation (EC) No 1935/2004).
• Chemicals : substances and mixtures, SDS and eSDS, monitoring of Annexes XIV and XVII (see our page chemicals sector: substances and mixtures).
• Packaging : multi-material items where the split between article and product determines the result of the calculation.
• Cosmetics : packaging, applicators and accessories, to be treated as articles distinct from the contents.
• Manufacturing industry : complex assemblies, imports from outside the EU, customer requirements.

In all these sectors, the functions concerned are the same: Quality, Regulatory Affairs, Purchasing, Supply Chain, CSR and IT.

Taking action

Three elements are enough to frame a first discussion: the list of items placed on the market (with masses if available), the latest collection campaign and its response rates, and the precise requirement of a customer.

To explore the methods further:

• the supplier REACH compliance guide, the pillar page on the topic: breakdown, 0.1% w/w calculation, evidence table and 12-point audit checklist;
• collecting and maintaining safety data sheets ;
• covering uses through eSDS exposure scenarios ;
• calculating SVHC per article rather than per finished product ;
• SCIP notification for articles and complex objects.

The next step is concrete: start from your ten most critical articles and check, for each one, that the mass, the concentration and the list version are documented. What you cannot find in ten minutes is exactly the scope of the engagement.