As an article manufacturer outside the EEA, the Candidate List should be followed. This is because the recommendation list is not an official list, and imported articles from outside the EEA do not require authorization. "Authorization" applies to all substances of very high concern listed in Annex XIV, whether they are manufactured or imported as substances or mixtures. Imported articles are not subject to authorization. However, if these articles are manufactured within the EU, the manufacturer must obtain authorization for mixtures containing these substances.

It can be obtained from the official ECHA website. SVHC Candidate List: Related link.

It can be obtained from the official ECHA website. Annex XVII restricted substances list: Related link.

An article is an object which, during production, is given a specific shape, surface, or design that determines its function to a greater degree than its chemical composition. Therefore, an article is not necessarily a finished product. In other words, simple items such as electronic components and screws can also be considered articles.

No. Although the components are assembled during use and shipped disassembled in one box, according to the Guidance on Requirements for Articles (version 2.0), each individual component is considered a separate article. For example: DIY furniture.

The proposal has been rejected. Therefore, the concentration threshold is still calculated at the article level.

"Restriction" refers to the limitations or prohibitions on specific uses of substances listed in Annex XVII. "Authorization" refers to a process by which ECHA grants permission for a company to use substances of very high concern for specific purposes. The Authorization List is selected from the SVHC Candidate List, and priority substances subject to authorization can be found in Annex XIV of the REACH Regulation.

REACH does not provide a standard declaration or certificate format. Therefore, companies must determine their roles under REACH and comply with the relevant legal requirements accordingly. The European Chemicals Agency and international helpdesks can assist in answering questions. Third-party certification bodies may also help in understanding the regulatory framework and associated obligations.

Restricted substances in Annex XVII should be assessed based on homogeneous materials.

XRF is mainly used to detect elements with an atomic number greater than or equal to 17. It detects elements but cannot directly identify compounds. Since SVHCs are present in compound form, XRF is not suitable for SVHC detection.

To our understanding, under Article 33 of REACH, there is no grace period for newly added SVHC substances. Information communication throughout the supply chain must be updated immediately.

Printed materials and packaging are considered articles and are subject to the same requirements as other articles, with no differences.

The CLP Regulation refers to the Classification, Labelling and Packaging of substances and mixtures (EC Regulation No. 1272/2008). It adopts the United Nations' Globally Harmonized System (GHS) within the EU to establish a unified system for chemical classification and labeling.

Generally, no. However, manufacturers and importers of certain explosive articles are required to classify them. These must meet the definitions in Part 2.1 of Annex I of CLP before being placed on the market. Other articles are not subject to CLP classification, labeling, and packaging requirements. Nevertheless, article manufacturers or importers must still classify substances contained within articles under REACH Articles 7 and 9 if registration or notification obligations apply, including substances used for product and process oriented research and development (PPORD).

Registration obligations apply only when the total quantity manufactured or imported by a registrant exceeds 1 tonne per year (see Article 6 of REACH for details).

Yes. REACH requires assessment of their impact on human health and the environment. Potential registrants must first determine whether registration or exemption obligations apply, regardless of particle size. Once within the scope of REACH, different requirements may apply depending on size and hazard properties. As nanotechnology continues to evolve, additional requirements may be introduced to address specific characteristics of nanomaterials.

In principle, SGS follows ECHA’s Guidance on Requirements for Articles and applies the threshold at the article level for testing. However, some countries—France, Austria, Belgium, Norway, Denmark, Germany, and Sweden—argue that this approach may cause a dilution effect. They therefore advocate applying the 0.1% (w/w) threshold at the component level rather than the entire article.