The SVHC candidate list is the most frequently misread status in European chemical regulation. Being on it does not prohibit a substance, does not require authorisation, and does not by itself stop anything. What it does is switch on a set of communication duties — and those duties reach much further down the supply chain than most people expect.
What makes a substance an SVHC
Article 57 of REACH sets the grounds. A substance can be identified as of very high concern because it is:
- carcinogenic, mutagenic or toxic to reproduction in category 1A or 1B;
- persistent, bioaccumulative and toxic (PBT), or very persistent and very bioaccumulative (vPvB);
- identified case by case as giving rise to equivalent level of concern — endocrine disruptors and respiratory sensitisers have entered this way.
Identification follows a formal procedure with public consultation and a Member State Committee decision. It is not automatic from a classification.
Candidate list, authorisation list — not the same thing
The candidate list is the list of substances identified as SVHC. Inclusion triggers information duties immediately.
The authorisation list is Annex XIV. Substances move onto it from the candidate list by a separate prioritisation decision, and most never do. Once on Annex XIV and past its sunset date, use or placing on the market requires a specific authorisation for a specific use.
The candidate list is long and grows twice a year. Annex XIV is short. Treating candidate-list inclusion as a prohibition is wrong; treating it as insignificant is also wrong.
What inclusion actually requires
In a substance or mixture
The safety data sheet must reflect the identification, and section 15 states the status.
In an article — the duty most often missed
Article 33 applies to articles, not just to substances and mixtures. Where an article contains an SVHC above 0.1 % by weight, the supplier must give the recipient sufficient information for safe use, as a minimum the name of the substance. On request from a consumer, the same information must be provided free of charge within 45 days.
This catches companies who consider themselves outside chemical regulation entirely — a manufacturer of finished goods with no safety data sheets anywhere in the business can still owe an Article 33 communication.
SCIP
Since 2021, suppliers of articles containing candidate list substances above 0.1 % must also notify the SCIP database maintained by ECHA. This is a separate duty from Article 33 communication and is not discharged by it.
The 0.1 % threshold, and what it is measured against
The threshold applies to the article. Where an article is composed of several articles joined together, the Court of Justice has held that the threshold applies to each component article rather than to the whole — which raises the number of cases that cross it, sometimes considerably.
Beyond the EU
The United Kingdom operates its own list under UK REACH, which started from the EU list at the end of the transition period and has since diverged. Australia, Canada and the United States maintain unrelated inventories with different criteria and different consequences.
A substance can therefore be a candidate-list SVHC in the EU and carry no equivalent status elsewhere, or the reverse. Inventory status is jurisdiction-specific and does not travel with the substance.
What absence from the list means
It means the substance has not been identified. It does not mean it was examined and cleared. Most substances have never been assessed against Article 57 at all, and reading a blank as an all-clear is the single most common way a chemical document misleads its reader.
On MolGod, inventory status is shown per list and per jurisdiction, and where a status is not established the page says so. That is the same rule that governs every other field: no data means no claim.
Legal basis: Regulation (EC) No 1907/2006 (REACH), Articles 33, 57 and 59, and Annex XIV. The candidate list is published and maintained by the European Chemicals Agency. MolGod.org is not affiliated with, endorsed by or accredited by ECHA.