What is the SVHC REACH Regulation?

For enterprises planning to sell products in the EU, REACH and SVHC are two unavoidable compliance keywords. Many enterprises have either incurRED extra costs due to excessive testing or had their goods detained for missing critical items, simply because they confused these two concepts. In fact, although both reach testing and SVHC testing fall under the EU Registration, Evaluation, Authorization and Restriction of CheMICals (REACH, EC 1907/2006) framework, they differ significantly in testing scope, objectives and compliance requirements. This article will clarify the relationship between the two from core definitions to practical applications, helping you accurately meet your compliance needs.

What is SVHC? What is REACH?

Simply put, REACH testing is a comprehensive compliance framework covering the entire life cycle of chemicals, while SVHC testing is a targeted screening for "high-risk substances" under the REACH system. The two have an inclusion relationship—SVHC testing is an important part of REACH testing, but not the whole.

1. Definitions and Coverage Scope

For example, if an enterprise produces plastic toys exported to the EU, REACH testing requires verifying whether the toys contain prohibited phthalates (e.g., DEHP) listed in Annex XVII, and confirming whether suppliers of the plastic raw materials have completed the registration of substances with an annual production capacity exceeding 1 ton. In contrast, SVHC testing focuses on whether the toys contain substances on the SVHC List (e.g., Short-Chain Chlorinated Paraffins) and whether their content exceeds 0.1%.

What are the Differences Between SVHC and REACH?

(1) Testing Objectives

REACH Testing: The core objective is to ensure that products comply with the full-chain requirements of the reach regulation, including both "restrictions" (prohibiting or limiting the use of hazardous substances such as lead and cadmium) and "registration" (chemical substances with an annual production capacity exceeding 1 ton must submit technical dossiers to the European Chemicals Agency, ECHA). The ultimate goal is to prevent products from being barred from the EU market for violating the regulation.

For example, a coating enterprise exporting to the EU conducting REACH testing must confirm that the solvent content in the coatings meets the limit requirements of REACH Annex XVII, and require coating raw material suppliers to provide proof of completed registration, to avoid supply chain information gaps.

SVHC Testing: The focus is to screen the content of high-risk substances in products and fulfill the information transmission obligation. If the content of a certain SVHC in a product is ≥ 0.1% by weight, the enterprise must provide safety use information (e.g., Safety Data Sheets, SDS) to downstream customers and consumers. If the annual export volume exceeds 1 ton, the enterprise must also submit a SCIP notification to ECHA, so that regulators and the public are informed of the presence of high-risk substances.

For example, if rubber gloves produced by an enterprise contain Short-Chain Chlorinated Paraffins listed on the SVHC List with a content exceeding 0.1%, even if the gloves meet other requirements of REACH Annex XVII, the enterprise still needs to provide the content information of this substance to purchasers. If the annual export volume of the gloves exceeds 1 ton, the enterprise must also complete the ECHA notification.

(2) Compliance Obligations

The enterprise obligations corresponding to REACH testing and SVHC testing are significantly different, which directly affect the compliance operation process.

Take an example: For an electrical and electronic enterprise exporting to the EU, REACH testing requires ensuring that the cadmium content in circuit boards is ≤ 100ppm (as restricted by Annex XVII), and confirming that suppliers of solders used in circuit boards have completed the registration of substances with an annual production capacity exceeding 1 ton. If the solder contains lead listed on the SVHC List (content ≥ 0.1%) and the enterprise's annual export volume of such circuit boards exceeds 1 ton, the enterprise must notify ECHA and indicate the presence of lead and safety precautions in the product specifications.

What are the Differences in Testing Methods and Report Applications?

1. Testing Methods: Similar Technical Means, Different Testing Focuses

Both adopt industry-common instrumental analysis methods, such as:

①　GC-MS (Gas Chromatography-Mass Spectrometry): For testing volatile organic compounds (e.g., Short-Chain Chlorinated Paraffins, Polycyclic Aromatic Hydrocarbons);

②　HPLC (High-Performance Liquid Chromatography): For testing non-volatile substances (e.g., Bisphenol A, Phthalates);

③　XRF (X-Ray Fluorescence Spectroscopy): For rapid screening of heavy metals (e.g., lead, cadmium, mercury).

④　However, their testing focuses are different: REACH testing needs to verify the compliance of both restricted substances in Annex XVII and substances requiring registration; SVHC testing only screens substances on the SVHC List one by one to confirm whether their content exceeds the limit.

2. Report Applications: One as a "Full Compliance certificate", the Other as a "High-Risk Substance Document"

①　REACH Testing Report: Comprehensive in content, covering test results of restricted substances and verification of supply chain registration information. It can be used as proof that products comply with the full-process requirements of EU REACH, applicable to scenarios such as customs clearance and customer factory audits.

②　SVHC Testing Report: Only lists the test results of substances on the SVHC List (e.g., substance name, content, compliance status). It is mainly used to fulfill the information transmission obligation (e.g., provided to downstream customers), complete ECHA notification, or serve as auxiliary proof that products are free of high-risk substances.

Must-Read for Enterprises: How to Determine Which Test is Needed?

1. Scenarios Where REACH Testing is Preferred

①　Products are pure chemicals (e.g., coatings, solvents, additives) with an annual production/import volume exceeding 1 ton;

②　Products are finished goods such as electrical and electronic products, textiles and toys, which need to pass testing to prove compliance with Annex XVII restriction requirements (e.g., limits on lead and phthalates);

③　Customers explicitly require a "full reach compliance report" for EU market access.

2. Scenarios Where SVHC Testing is Mandatory

①　Products are children's products, food contact materials or cosmetics (high-risk categories prone to containing SVHCs);

②　Customers require an "SVHC screening report" to confirm that products are free of high-risk substances;

③　Products may contain substances on the SVHC List (e.g., plastic products may contain Bisphenol A, rubber products may contain Short-Chain Chlorinated Paraffins), requiring screening to determine whether the content triggers the notification obligation.

3. Scenarios Where Both Tests are Required

Most finished product enterprises exporting to the EU (e.g., electrical and electronic products, toys, furniture) need to meet both requirements: they must pass REACH testing to ensure compliance with Annex XVII restrictions and supply chain registration requirements, and also conduct SVHC testing to screen for high-risk substances, avoiding missing notification obligations.

Notes

(1) Myth: "If REACH testing is done, SVHC testing is unnecessary."

Fact: Wrong. Although REACH testing includes some SVHC-related verification, its focus is on restricted substances and registration obligations. SVHC testing is a targeted screening to confirm whether notification and information transmission obligations are triggered—they are not mutually substitutable.

(2) Myth: "If SVHC content is < 0.1%, no action is needed at all."

Fact: Not entirely correct. Although notification is not required when content is < 0.1%, enterprises still need to retain test records. If customers request SVHC-related information, enterprises must truthfully inform them of the presence and content of the substances.

(3) Myth: "The SVHC List is static; one test is valid for a lifetime."

Fact: Wrong. ECHA updates the SVHC List every six months (usually in June and December). Enterprises need to regularly verify whether their products contain newly added SVHCs and conduct supplementary testing in a timely manner.

For enterprises exporting to the EU, distinguishing the differences between REACH testing and SVHC testing is the first step toward accurate compliance. It is recommended that enterprises first sort out product components (e.g., whether raw materials contain high-risk substances, whether annual export volume exceeds 1 ton), then select the corresponding testing items based on customer requirements and EU regulatory updates. If there are any doubts about the testing scope or compliance obligations, enterprises can seek support from professional testing institutions like JJR LAB. Through services such as component analysis and pre-testing, enterprises can ensure that their products not only meet the full-process requirements of REACH but also comply with the targeted compliance obligations of SVHC, enabling smooth access to the EU market.