SVHC vs SCIP vs REACH Annex XVII: Which Obligation Applies to Your SKU?

Managing compliance for a large SKU range means your product data must carry more than a description and a price. When a supplier feed arrives with missing CAS numbers, ambiguous concentration ranges, or blank safe-use fields, every EU REACH obligation downstream — SVHC screening, SCIP notification, Annex XVII restriction checks — becomes a manual fire drill. Distributors regularly conflate all three as a single “REACH task,” but they are distinct obligations that trigger at different points, demand different data, and carry different consequences if the underlying product record is incomplete.

Claro keeps product and supplier data trusted as catalogs change: it resolves substance identity across feeds, enriches missing compliance attributes with traceable provenance, validates updates against each new Candidate List release, and writes clean records back into your PIM or ERP so SVHC, SCIP, and Annex XVII checks run against data you can actually defend.

What each obligation is

All three stem from EU REACH (Regulation 1907/2006), but they operate at different layers of the same regulation:

• SVHC Candidate List — the list of Substances of Very High Concern maintained by ECHA, updated approximately twice a year. Presence of a listed substance above 0.1% by weight in an article triggers a communication duty down the supply chain.
• SCIP Database — an ECHA notification database operated under the Waste Framework Directive. If an article placed on the EU market contains an SVHC above the 0.1% threshold, you must submit a dossier to SCIP before placing it on the market.
• REACH Annex XVII — the restriction list. Each entry sets substance-specific limits and use conditions. This is a pass/fail gate: a product containing a restricted substance above its limit cannot be sold in the EU, regardless of disclosure.

They build on each other sequentially. A substance can appear on the SVHC Candidate List (triggering a communication duty), generate a SCIP notification obligation, and later move to Annex XVII restriction. Tracking only one of the three leaves a visible gap in any compliance audit.

Side-by-side comparison

Before and after: compliance data quality

The common failure mode is not a wrong answer but missing data — substance fields that were never populated, CAS numbers that reference a different substance, or concentration values copied as free text rather than structured ranges.

When each obligation applies

SVHC Candidate List

Treat the SVHC list as your screening layer. Whenever you onboard a new supplier range, check declared substances against the current Candidate List. For a CPG brand importing packaging or a distributor handling industrial coatings, this is where compliance starts: identify whether any SVHC is present above 0.1% by weight in any article. If it is, you have a duty to communicate that down the supply chain, including to consumers on request within 45 days. Because ECHA adds substances approximately twice a year, ongoing re-screening of your existing catalog is a standing requirement, not a one-time task.

SCIP Database

SCIP is where screening becomes a reporting obligation. If an article placed on the EU market contains an SVHC above the threshold, you must submit a SCIP dossier to ECHA. A furniture distributor importing chairs with treated textiles, or an MRO supplier stocking seals with a flagged plasticizer, needs the article identifier, the substance identity, a concentration range, and safe-use instructions in the dossier. Missing or incomplete SCIP data is a common reason products are blocked at the border or rejected by EU marketplaces — and the root cause is almost always an incomplete product record, not a genuine compliance failure.

REACH Annex XVII

Annex XVII is the hard line. It restricts or bans specific substances in specific uses, with no general 0.1% rule: each entry sets its own limit and the intended-use scope. This is a pass/fail gate, not a disclosure duty. An industrial distributor selling cables, a furniture importer using flame retardants, or a CPG brand with certain pigments must confirm the substance stays under the restricted limit for the intended use. Above the limit, the product cannot be sold in the EU, and no amount of SCIP filing or SVHC communication changes that.

Related

FAQ

Is SCIP the same as the SVHC Candidate List? +

No. The SVHC Candidate List is the list of substances of concern maintained by ECHA. SCIP is a separate ECHA database where you notify that an article contains one of those substances above 0.1% by weight. The SVHC list tells you what to watch for; SCIP is where you report it. Missing the distinction means you may screen correctly but never file the required dossier.

What is the difference between REACH Annex XVII and the SVHC list? +

The SVHC Candidate List creates a duty to communicate that a substance is present in an article above the threshold. Annex XVII is a restriction list that bans or limits substances outright in specific uses. A substance on the SVHC list can still be sold with proper disclosure; a substance restricted under Annex XVII above its limit cannot be sold in the EU at all.

Does a SCIP notification apply to every product? +

Only to articles placed on the EU market that contain an SVHC above 0.1% by weight. If no SVHC is present above the threshold, no SCIP dossier is required. That is why SVHC screening comes first: it determines whether the SCIP obligation is triggered at all.

What data do I need to manage all three obligations at scale? +

At minimum you need a validated substance identifier (CAS or EC number), the concentration in each article, the article identifier, and safe-use information. Holding these as canonical fields with traceable provenance lets you run SVHC screening, generate SCIP dossiers, and check Annex XVII limits from one source of truth rather than three separate spreadsheets. Claro attaches a source link to every compliance attribute so every value can be audited.

How often does the SVHC Candidate List change? +

ECHA typically updates the Candidate List about twice a year, in winter and summer. Because new substances are added regularly, screening once at supplier onboarding is not enough. Re-checking your catalog against each update is a standing compliance task, not a one-off project.

Can incomplete supplier data create a SCIP gap even when screening passes? +

Yes. A supplier may declare no SVHC presence, but if the underlying substance identity (CAS number, concentration) is missing or malformed in their feed, you cannot verify the claim. Distributors who treat the supplier declaration as the final answer, rather than validating the underlying data fields, routinely discover SCIP gaps only when a product is blocked at an EU border or rejected by a marketplace.