Informational summary for procurement, R&D, and compliance teams. Not legal advice. For binding interpretation consult counsel and the ECHA REACH guidance directly.
REACH in one paragraph
Regulation (EC) No 1907/2006 — REACH, “Registration, Evaluation, Authorisation and Restriction of Chemicals” — entered force on 1 June 2007. It places the burden of demonstrating safe use on manufacturers and importers of chemical substances placed on the EU market. Four core obligations operate in parallel: registration (substances at or above 1 tonne/year), evaluation (dossier and substance review by ECHA and Member States), authorisation (Annex XIV, substances of very high concern), and restriction (Annex XVII, prohibitions or conditions on specific substances). It applies to substances, mixtures, and articles.
The SVHC Candidate List — what it is
The Candidate List of Substances of Very High Concern (SVHC) is maintained by ECHA. A substance is added if it meets one or more of the Article 57 criteria: CMR category 1A or 1B (carcinogenic, mutagenic, toxic to reproduction); PBT (persistent, bioaccumulative, toxic); vPvB (very persistent, very bioaccumulative); or substances of equivalent level of concern such as endocrine disruptors. The list grows twice per year, typically in January and June.
As of November 2025 the list contains 253 substances. Candidate List inclusion is the entry point to potential Authorisation List status, but it is not a prohibition by itself. The immediate effect is to trigger duties of communication and notification along the supply chain.
Annex XIV vs Annex XVII — the two regulatory instruments
REACH provides two separate instruments for SVHC and other substances of concern. Suppliers, downstream users, and procurement teams need to track both, but the mechanics differ.
| Attribute | Annex XIV (Authorisation List) | Annex XVII (Restriction List) |
|---|---|---|
| Legal mechanism | Per-actor, per-use authorisation | Universal condition or prohibition |
| Trigger to enter | SVHC identification + prioritisation | Annex XV restriction dossier |
| Effect on substance | Sunset date; need authorisation past sunset | Restricted as written (often complete ban) |
| Number of substances (Nov 2025) | ~70 entries | ~80 entries (each may cover many substances) |
| Geographic scope | EU placement on market | EU manufacture, import, and use |
| Article import exemption | Articles imported with substance not requiring authorisation | Imported articles in scope as written |
| Procurement implication | Verify supplier's authorisation status per use | Confirm formulation does not contain restricted substance in restricted scope |
The 0.1% w/w threshold and what it triggers
Once a substance is on the Candidate List, suppliers of articles containing it above 0.1% w/w must:
- Notify ECHA (Article 7(2)) — within 6 months of inclusion if the article quantity exceeds 1 tonne/year and the substance presence above 0.1% w/w in the article.
- Inform the recipient of the article (Article 33(1)) — providing the substance name and sufficient information for safe use, free of charge.
- Inform consumers on request (Article 33(2)) — within 45 days, free of charge.
- Notify the SCIP database (under the Waste Framework Directive, Article 9(1)(i)) — for any article placed on the EU market.
The 0.1% calculation is per article, not per assembled product (ECJ ruling C-106/14, 2015). For coated polymer films, this means the coating chemistry and the substrate are each evaluated as articles. For a glazing assembly, each pane, each interlayer, and each surface coating is a separate article for the 0.1% test.
The SVHC notification cycle in practice
| Phase | Trigger | Typical timeline |
|---|---|---|
| 1. Annex XV submission | Member State or ECHA dossier for SVHC identification | ~12 months before Candidate List entry |
| 2. Public consultation | ECHA publishes dossier | 45 days |
| 3. MSC opinion | Member State Committee decision | ~3 months |
| 4. Candidate List inclusion | ECHA publication (Jan and June) | Article 33 communication duties start immediately |
| 5. Article 7(2) notification | Articles in scope above 0.1% w/w and 1 t/yr | 6 months after inclusion |
| 6. Prioritisation for Annex XIV | ECHA recommendation to Commission | 12 – 36 months after inclusion |
| 7. Authorisation sunset | Commission Decision listing in Annex XIV | Typically 18 – 42 months after listing |
Source: REACH Articles 33, 7(2), 58, 59; ECHA published procedure. Timelines indicative.
How Kriya tracks the SVHC list — Drift Alerts
Kriya operates an internal regulatory monitoring system (Drift Alerts) that watches:
- The ECHA Candidate List (253 substances as of November 2025) — change detection within 24 hours of publication
- RAC and SEAC adopted opinions
- Annex XV registry of intentions (forward-looking restriction proposals)
- The SCIP database for any article presence reports involving Kriya supplier chains
- Member-State proposals under CLP harmonised classification (CMR upgrades that feed SVHC pipeline)
- U.S. state-level chemical restrictions and Asian regulatory equivalents (Korea K-REACH, Japan CSCL, China MEP)
Each Kriya raw material is mapped to its SVHC status and forward-looking risk score. When the list changes, the impacted formulations, customer programmes, and Safety Data Sheets are flagged for update. Customer-facing disclosure refreshes within 30 days of ECHA publication.
For more on Kriya security and disclosure infrastructure see security and vulnerability disclosure.
Downstream user communication — what suppliers owe
Under Article 31, suppliers of substances and mixtures must provide a Safety Data Sheet (SDS) in the official languages of the Member States where the product is placed on the market. The SDS must be updated without delay when new information affecting risk management measures becomes available, when an authorisation is granted or refused, or when a restriction is imposed.
Under Article 32, suppliers of substances and mixtures not requiring an SDS must still pass on registration numbers, authorisation status, restriction details, and any other available information needed for safe use.
Kriya provides:
- SDS per product in 8 languages (EN, NL, DE, FR, IT, ES, JA, KO)
- Certificate of Analysis per batch documenting key composition parameters
- SVHC declaration per formulation on request
- Total Organic Fluorine analytical confirmation for PFAS-free verification
- Annual material disclosure refresh aligned to the ECHA update cycle
PFAS and REACH — overlap, not duplication
Several PFAS substances are already on the Candidate List (PFOA, PFOS, PFHxS, PFNA, HFPO-DA, and others). Several are on Annex XVII as standalone restrictions (PFOA restriction in force 2020, PFHxA restriction phased from 2026). The broader Universal PFAS Restriction Proposal under SEAC and RAC review is the bulk pathway covering approximately 10,000 substances. Annex XIV authorisation route is also possible for individual PFAS subgroups.
For PFAS-specific timeline and impact analysis, see the EU PFAS restriction timeline brief. For the underlying PFAS-free coating technology, see PFAS-free coatings.
Frequently asked questions
Is being on the SVHC Candidate List the same as being banned?
No. Candidate List inclusion is identification of Substances of Very High Concern but does not by itself restrict use. It triggers (1) communication duties along the supply chain, (2) SCIP database notification for articles containing the substance above 0.1% w/w, and (3) potential future move to Annex XIV (Authorisation List) or Annex XVII (Restriction List). Many substances remain on the Candidate List for years without further restriction; some are restricted within 2 to 4 years.
What is the 0.1% w/w threshold and what does it apply to?
The 0.1% weight-by-weight threshold determines whether an article (a finished object with a specific shape) is in scope for SVHC communication and notification duties. The European Court of Justice ruling in case C-106/14 (2015) clarified that 0.1% is calculated per individual component article, not per assembled product. For coated films and substrates, the coating layer is generally treated as part of the article; trace SVHC content above 0.1% in the formulation can put the finished article in scope.
What is the difference between Annex XIV and Annex XVII?
Annex XIV (Authorisation List) requires manufacturers and importers to apply for an authorisation per use, with a sunset date after which the substance cannot be placed on the market without authorisation. Annex XVII (Restriction List) places direct conditions or prohibitions on manufacture, placing on the market, or use of a substance — no per-actor authorisation needed; the rule applies universally to the listed substance in the listed scope. Authorisation is the more restrictive instrument; restriction is the broader instrument.
How does Kriya track the SVHC list?
Kriya operates an internal monitoring system (codenamed Drift Alerts) that watches the ECHA Candidate List, RAC and SEAC opinions, Annex XV registry of intentions, and the SCIP database for changes affecting any raw material or formulation. The Candidate List currently contains 253 substances (as of November 2025; ECHA updates twice yearly in January and June). Each Kriya raw material is mapped to its SVHC status; changes propagate to a customer-facing material disclosure register within 30 days of ECHA publication.
Do Kriya coatings contain SVHC substances above 0.1% w/w?
No SVHC currently listed in Annex XIV is intentionally added to any Kriya production formulation. Trace presence of any Candidate List substance above the 0.1% w/w threshold is documented per Safety Data Sheet section 3 and Certificate of Analysis. For specific verification per formulation and per batch, request the disclosure statement via the contact channel below.