REACH SVHC declarations for merch materials

What it requires

• Screen every article (textile, plastic, leather, electronics) against the SVHC list
• Notify ECHA within 6 months if SVHC > 0.1% w/w + tonnage > 1 t/yr
• Provide downstream-user information (Article 33) on request, free of charge
• Respond to consumer Article 33(2) requests within 45 days
• Submit SCIP database entry for every article placed on EU market with SVHC > 0.1%
• Maintain Safety Data Sheets (SDS) for chemical mixtures (e.g., printing inks)
• Verify Annex XVII restrictions (e.g., azo dyes, lead, cadmium) per category

How it impacts merch programs

• PVC products often contain phthalates: common SVHC trigger
• Lead-soldered electronics (USB cables) may exceed 0.1% at the joint
• Leather goods can carry chromium VI from tanning if non-LWG
• Plastic bottles with bisphenols (BPA, BPS) frequently flagged
• PFAS in waterproof bag coatings increasingly added to SVHC list
• Imported textiles dyed with restricted azo dyes blocked at EU border

Documentation packet — what suppliers must provide

1. Per-SKU SVHC declaration on supplier letterhead
2. Test reports from accredited (ISO 17025) labs: TUV, SGS, Intertek, BV
3. SCIP database submission ID per article
4. Annex XVII compliance statement
5. Safety Data Sheets for inks, adhesives, coatings
6. Material declaration with full bill-of-substances above 0.1%
7. Certificate of conformity signed by supplier QA
8. Test method references (e.g., EN 71-3, EN 14362-1)

Decision tree — when does this framework apply?

• Will the merch be placed on the EU/EEA market? REACH applies
• Does the article weigh > 1 t in aggregate annual EU placement? Notification trigger
• Is any candidate-list substance > 0.1% w/w? Communication duty
• Is the substance restricted under Annex XVII? Outright prohibition or limit

Penalties for non-compliance

• Per-Member-State enforcement: fines from EUR 2 000 to over EUR 1 million
• Product seizure at EU border or from market
• Criminal liability for repeat or wilful breach in some jurisdictions
• Public listing on RAPEX (EU rapid alert) for unsafe products

How we help

• Pre-cleared SVHC declarations on file for every catalogue SKU
• Annual ISO-17025 test report cycle on textile, plastic, leather lines
• SCIP database submission handled on your behalf
• Annex XVII screening with stop-shipment alert for new restrictions
• Phthalate-free, BPA-free, PFAS-free options across drinkware and bags
• 45-day Article 33(2) consumer-response service

Related frameworks

• Rohs Electronics Merch
• Cbam Carbon Border
• Csrd Procurement

Related resources

• Glossary of compliance terms
• Material catalogue
• Sustainability report 2026
• Data Processing Addendum
• Whitepapers and reports

Frequently asked questions

Does the 0.1% rule apply per article or whole product?

European Court (C-106/14) confirmed once-an-article-always-an-article: 0.1% applies to each component article.

How do we know which substances are SVHC?

ECHA publishes the Candidate List; we screen against the latest version with each shipment.

What is SCIP?

ECHAs Substances of Concern in Products database: submission required for any article with SVHC > 0.1% placed on EU market.

Can we ignore Article 33 if were a non-EU brand?

No: once your products are placed on the EU market by you or via your distributor, Article 33 applies.

Does Article 33(2) apply to consumers receiving free promotional items?

Yes: they are still consumers under REACH; the 45-day response window applies.