REACH compliance for electronic components means knowing which substances of very high concern (SVHCs) are present in the parts you buy, above which threshold, and what you are then obliged to pass on. REACH is Regulation (EC) No 1907/2006, it entered into force on 1 June 2007, and it is administered by the European Chemicals Agency (ECHA). Unlike RoHS, REACH is a regulation rather than a directive, so it binds every supplier of an article placed on the EU market directly, with no national transposition step.
Most guides stop at a definition. This one is for the person who has to answer a customer audit: the thresholds, the annexes that behave differently, the 45 day clock, and the one obligation almost every component article leaves out.
REACH vs RoHS: the difference that matters when you buy parts
Buyers routinely treat these as one compliance box. They behave very differently. If you need the RoHS side in depth, read our guide to RoHS compliance for electronic components. The short version:
| Dimension | RoHS (Directive 2011/65/EU) | REACH (Regulation (EC) No 1907/2006) |
| Legal form | Directive, transposed into national law | Regulation, directly binding across the EU |
| Scope | Electrical and electronic equipment only | All substances in any article placed on the EU market |
| Substance list | Fixed: 10 restricted substances (RoHS 3, (EU) 2015/863) | Open and growing: the SVHC Candidate List, plus Annex XIV and Annex XVII |
| Threshold | 0.1% by weight in homogeneous material (0.01% for cadmium) | 0.1% by weight per article |
| Core duty | Do not place non compliant equipment on the market | Communicate SVHCs down the chain, notify ECHA, seek authorisation where required |
Put simply: RoHS is a fixed banned substance checklist for the finished device. REACH is a living chemical transparency regime that reaches every article, every tier, and every distributor, including yours.
SVHCs, the Candidate List and the 0.1% threshold
A substance of very high concern is one ECHA has identified as carcinogenic, mutagenic, toxic for reproduction, persistent and bioaccumulative, or of equivalent concern. Those substances go onto the SVHC Candidate List, which ECHA updates roughly twice a year. As of 4 February 2026 the Candidate List contains 253 entries, following the addition of n-hexane and bisphenol AF.
The number that governs your obligations is 0.1% by weight. If an SVHC is present above 0.1% w/w in an article, communication duties are triggered. The important subtlety, and one that trips up buyers, is what counts as an "article". Following a Court of Justice ruling of 10 September 2015 (commonly called the "once an article, always an article" principle), the 0.1% threshold is applied to each article within a complex object, not to the object as a whole. A capacitor inside an assembly is assessed as a capacitor, not diluted across the whole board. This makes threshold breaches far more common than a naive calculation suggests.
The three REACH lists that behave differently
- Candidate List: identification only. A part containing a listed SVHC above 0.1% is still legal to buy and use, but it carries communication and notification duties.
- Annex XIV (Authorisation): after a substance's sunset date, its use in the EU requires a granted authorisation. This is the list that can stop a design.
- Annex XVII (Restriction): outright bans or conditions of use that apply regardless of authorisation.
Registration is a separate track: substances manufactured or imported at one tonne or more per year must be registered with ECHA, and a chemical safety report is required at ten tonnes or more per year. Registration duties fall on manufacturers and importers of substances, not on a buyer purchasing finished components.
Article 33 and the 45 day rule
Under Article 33 of REACH, any supplier of an article containing an SVHC above 0.1% w/w must provide the recipient with sufficient information for safe use, as a minimum the name of the substance. On request from a consumer, that information must be supplied free of charge within 45 days. This duty sits with the supplier of the article, which includes distributors. When you ask your distributor for an SVHC declaration, you are not making an unusual request. You are asking them to do something REACH already requires.
SCIP: the obligation most component articles ignore
This is the gap. SCIP is ECHA's database of Substances of Concern In articles as such or in complex objects (Products). Since 5 January 2021, under the Waste Framework Directive (2008/98/EC), any EU supplier placing an article on the market that contains a Candidate List SVHC above 0.1% w/w must submit a SCIP notification to ECHA.
A SCIP notification number is therefore hard evidence that a supplier has met the duty rather than merely claiming compliance. For any affected part, ask for it. A supplier who can name the SVHC but cannot produce a SCIP number has done half the job.
What to request from your distributor, per part
- A REACH/SVHC declaration stating SVHC present yes or no, and if yes, the substance name, CAS number, and whether it exceeds 0.1% w/w.
- The Candidate List version or date the declaration was made against. An undated declaration is worthless six months later.
- A SCIP notification number for affected articles.
- A RoHS declaration of conformity alongside it, since the two are not interchangeable.
- Traceability back to the source, which matters most when parts come from the open market. See our guidance on how to avoid counterfeit electronic components.
Treat "vendor undefined" as a data gap you must chase, not as a pass. It means nobody has answered the question.
What to do when a part contains an SVHC above the threshold
It is not automatically a stop. The part remains legal to purchase and use unless the substance appears on Annex XIV past its sunset date without an authorisation covering your use, or is restricted under Annex XVII. What changes is that you inherit downstream duties: pass the safe use information on, answer consumer requests within 45 days, and satisfy yourself that a SCIP notification exists for that article. Decide deliberately whether to accept the part with documentation, or to design it out and start a second source conversation early.
Build re-screening into procurement, not into panic
Because the Candidate List grows about twice a year, a part that is clean today can acquire an SVHC at the next update without anything about the part changing. Compliance is not a one time check at qualification. Set a re-screening cadence tied to the ECHA update cycle, hold supplier declarations that are dated to a specific Candidate List version, and re-request declarations for critical parts after each update. Doing this on a calendar is far cheaper than doing it during a customer audit.
How GlobX supports REACH documentation
GlobX is an ISO 9001 certified independent distributor based in Neu-Isenburg, Germany, supplying OEM and EMS buyers across Europe since 2012. Because we sit inside the EU, REACH duties apply to us as a supplier of articles, not as a distant third party. We supply compliance documentation with the parts we ship, maintain full traceability and certificates of conformance, and run anti-counterfeit checks on open market sourcing. If you are chasing declarations for a hard to find part, our sourcing services and component catalogue are the place to start, or you can talk to our team and get a quote within 24 hours.
Frequently asked questions
Is a component containing an SVHC above 0.1% illegal to buy?
No. It remains legal to purchase and use unless the substance is listed on Annex XIV past its sunset date without an authorisation, or is restricted under Annex XVII. What the threshold triggers is a duty to communicate the SVHC down the supply chain and to ensure a SCIP notification has been submitted to ECHA.
What is the difference between RoHS and REACH compliance for a part?
RoHS restricts a fixed list of 10 substances in electrical and electronic equipment, measured at 0.1% by weight in homogeneous material. REACH is an open regime covering all substances in any article, measured at 0.1% by weight per article, with a Candidate List that grows about twice a year and separate authorisation and restriction annexes.
How quickly must a supplier give me SVHC information?
Under Article 33 of REACH, a supplier of an article containing an SVHC above 0.1% w/w must provide sufficient safe use information, at minimum the substance name. On a consumer request this must be provided free of charge within 45 days.
What is a SCIP number and why should I ask for it?
SCIP is ECHA's database of Substances of Concern In articles. Since 5 January 2021, EU suppliers of articles containing a Candidate List SVHC above 0.1% w/w must notify ECHA. A SCIP notification number is proof the obligation was met, which is why you should request one for every affected part rather than accepting a compliance claim on its own.