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SVHC and SCIP: The 0.1 % Threshold
The REACH threshold applies to each article, not to the assembled product. That single distinction accounts for most notifications that turn out to be required.
REACH requires communication when a substance of very high concern is present above 0.1 % by weight in an article, and the same data must be notified to the ECHA SCIP database. The threshold applies per article, not across the finished product, which is where most assessments go wrong.
What this gives you
How the 0.1 % threshold is calculated and on which article, what SCIP notification requires, and how to hold substance data so both obligations are answered once.
Key takeaways
- The 0.1 % threshold is calculated per article — a component — rather than across the assembled product.
- SCIP notification and the Article 33 duty to inform recipients are separate obligations; satisfying one does not satisfy the other.
- The candidate list updates roughly twice a year, so a completed screening has a shelf life.
- Substance location matters as much as presence, because that is what a treatment facility acts on.
Substance compliance produces more retrospective corrections than any other passport attribute, and almost all of them trace to one misunderstanding about how a percentage is calculated.
The rule is that a substance of very high concern present above 0.1 % by weight in an article triggers duties. The trap is in the word article, which does not mean the product a customer buys.
What counts as an article
Under REACH an article is an object given a special shape, surface or design which determines its function to a greater degree than its chemical composition. A screw is an article. A cable is an article. A moulded housing is an article.
A product assembled from many articles does not become one article. Each component retains its status, and the threshold is assessed against each of them separately.
| Basis of calculation | Result | Correct? |
|---|---|---|
| Substance mass ÷ mass of the whole product | 0.008 % — below threshold | No |
| Substance mass ÷ mass of the component | 0.4 % — above threshold | Yes |
| Substance mass ÷ mass of the subassembly | Varies with how the assembly is drawn | No |
Two obligations, not one
Where a substance is above threshold, two separate duties arise and they are frequently confused.
- Article 33 communication. Suppliers must give recipients sufficient information to allow safe use, including at minimum the name of the substance. Consumers can request the same information and must receive it within forty-five days.
- SCIP notification. The same data must be notified to the ECHA database established under the Waste Framework Directive, so that waste operators can access it. This produces a submission number.
They serve different audiences — one the supply chain, the other waste treatment — and completing one does not discharge the other. A company that has notified SCIP but does not answer consumer requests within the deadline is non-compliant with Article 33 regardless.
The candidate list moves
The list of substances of very high concern is updated periodically, typically twice a year. A substance that was unlisted when a product was assessed can be added later.
This makes substance screening a recurring obligation rather than a project. A screening completed against the January list is not a screening against the June list, and products in continuous production remain exposed to each update.
The operational answer is to hold full material declarations rather than only a compliance conclusion. A stored declaration can be re-screened against a new list in minutes; a stored yes-or-no answer requires the entire supplier exercise again.
Location, not just presence
Both the passport and the recycler need to know where a substance sits, not merely that it is somewhere in the product.
A declaration naming the component allows a treatment facility to route that fraction separately and an installer or repairer to avoid releasing it. A declaration naming only the product forces a facility to treat everything as contaminated or ignore the information, and both outcomes waste the compliance work that produced it.
What a repairer or dismantler must avoid doing.
Which article contains it, not merely which product.
Calculated per article, with the basis stated.
Name and CAS number, from the current candidate list.
Where the data usually comes from
Full material declarations arrive through one of three routes, and they differ in reliability more than most buyers assume.
An industry-standard declaration format completed by the supplier is the strongest, because the schema forces completeness. A supplier statement of compliance against the candidate list is weaker, since it records a conclusion rather than the underlying composition and cannot be re-screened. A laboratory test on a finished sample is authoritative for what it covers and expensive enough that it is rarely repeated when a component changes.
Making the screening tractable
The exercise becomes manageable when the bill of materials is the starting point rather than a supplier questionnaire.
A structured bill of materials with mass per component turns screening into a calculation. Without one, every candidate list update triggers a fresh round of supplier correspondence, which is why companies that treat this as a data problem spend a fraction of what companies treating it as a compliance exercise spend.
That is also precisely the data a passport requires, which makes substance compliance one of the clearest cases where the regulatory obligation and the passport programme are the same work.
Frequently asked questions
How is the 0.1 % threshold calculated?
Against the mass of the article containing the substance, not the assembled product. A component that is 0.4 % of a restricted substance remains above threshold even where it represents a small fraction of the finished item, and calculating against the whole product is the most common assessment error.
What is the difference between Article 33 and SCIP?
Article 33 requires communication to recipients and, on request, to consumers within forty-five days. SCIP notification puts the same data in an ECHA database for waste operators. They serve different audiences and completing one does not discharge the other, though both arise from the same finding.
How often must screening be repeated?
Whenever the candidate list is updated, which is typically twice a year, and whenever a component or a supplier changes. Holding full material declarations rather than only a compliance conclusion makes re-screening a calculation you can run in minutes rather than a fresh round of supplier correspondence.
Do we need to declare substances below the threshold?
Not under Article 33, though recording them is useful. A substance at 0.08 % today can exceed the threshold after a minor formulation change, and holding the underlying figure means the reassessment is immediate rather than requiring the supplier exercise to be repeated.
Who is responsible when a supplier provides the data?
The party placing the product on the market. Supplier declarations are the evidence rather than a transfer of liability, which is why recording who asserted each figure and when matters. An authority asking for the basis of a declaration expects an answer from you, not a referral.
What if a supplier will not provide full composition?
This is usually a confidentiality concern rather than refusal, and is normally resolved by a declaration against the candidate list rather than a full formulation disclosure. Where a supplier cannot confirm even that, the component carries an unquantified risk that should be escalated commercially.
Does this connect to the Digital Product Passport?
Closely. The passport carries substance data as a recycler- and regulator-visible attribute, and the structured bill of materials that makes screening tractable is the same input the passport needs. Companies running them separately duplicate the supplier work and produce inconsistent records.
Sources
- Regulation (EC) No 1907/2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) — EUR-Lex, European Union, 2006-12
- Directive 2008/98/EC on waste (Waste Framework Directive) — EUR-Lex, European Union, 2008-11
Continue reading
- What recyclers need from manufacturersWhy substance location matters more than presence on a dismantling line.
- What data must a Digital Product Passport contain?Where substance data sits among the passport attribute families.
- Getting data out of deep-tier suppliersHow to obtain the material declarations screening depends on.
- Compliance checklistsA working substance screening checklist you can run against a product.