Ultimo aggiornamento 16 June 2026
SVHC and REACH compliance for sensitive supply chains
When a company supplies components, mixtures, surface treatments, or technical products to large industrial groups, REACH compliance becomes a practical issue involving supplier qualification, business continuity, and document reliability.
This is especially true in supply chains that are highly sensitive to hazardous substance issues, such as defense, aerospace, electronics, advanced mechanical engineering, and specialized treatments. In these contexts, customers do not simply request a standard declaration; they often require precise information for each individual part number, verification of the presence or absence of SVHCs, clarity on the REACH status of the substances used, and consistency between declarations, safety data sheets, and the information received from subcontractors.
This is exactly where many companies face challenges, because they need to translate complex regulatory requirements into precise, defensible, and consistent technical solutions throughout the entire supply chain.
To address these requests properly, the first step is to understand what SVHCs are and why they are so closely monitored.
What are SVHCs?
SVHCs are Substances of Very High Concern, meaning substances identified under the REACH Regulation as posing a particularly high level of concern. This category includes, for example, substances that are carcinogenic, mutagenic, or toxic to reproduction, as well as persistent, bioaccumulative, and toxic substances; very persistent and very bioaccumulative substances; and substances of equivalent level of concern.
When a substance is identified as an SVHC, it may be included in the Candidate List. This step is far from theoretical: inclusion in the Candidate List triggers specific obligations for manufacturers, importers, downstream users, and suppliers of articles, and it may represent the first sign of a future regulatory development toward authorization or other risk management measures.
For companies operating in complex supply chains, this means one very simple thing: You need to understand whether it is present in your products, in what form, at what concentration, and what the associated regulatory and commercial implications are.
The duty of care when dealing with SVHCs
SVHCs are often mistakenly thought to be subject to an automatic ban. In reality, the framework is more complex.
1. Presence of SVHCs and communication throughout the supply chain
If a substance is included on the Candidate List, the company must first determine where it is found: in the substance itself, in a mixture, in an article, in a treatment, or in a stage of the manufacturing process.
Different obligations may then apply. For substances and mixtures, the safety data sheet may need to be updated. For articles, the presence of SVHCs above certain thresholds may trigger a requirement to inform customers and, in some cases, submit specific notifications.
For many supplier companies, the practical challenge is not only regulatory but also administrative: the available information is often scattered across safety data sheets (SDSs), supplier declarations, technical data from subcontractors, and customized requests from the end customer.
2. Being on the candidate list does not automatically imply authorization
Another key point is the distinction between SVHCs, authorization, and restriction.
Inclusion on the Candidate List does not automatically mean inclusion in Annex XIV. However, some SVHCs may be prioritized and become subject to authorization. In that case, after the so-called “sunset date,” the substance may no longer be used without a specific authorization covering that use.
For suppliers in sectors such as aerospace or defense, this point is crucial. It is not enough to simply state whether a substance is present or absent; it is necessary to determine whether it is subject to the authorization regime, whether there are covered uses, whether the supply chain is operating under upstream authorizations, or whether the issue relates solely to a preventive regulatory risk assessment.
3. Restriction: a different but closely related topic
In addition to authorization, there is also the restriction system, which may limit or prohibit the manufacture, placing on the market, or use of a substance on its own, in a mixture, or in an article. Restrictions follow a different approach than authorization and require a specific assessment of the actual use of the substance.
This is essential to avoid common mistakes, such as declaring a product as “REACH-compliant” without verifying whether the substances involved are listed on the Candidate List, Annex XIV, or Annex XVII, or without checking whether the actual use within the customer’s supply chain raises additional concerns.
Why suppliers to large industrial groups need real control
When a customer—such as a prime contractor or a large industrial group—requests an SVHC declaration or confirmation of REACH compliance, they are asking for much more than just a standard form letter.
In practical terms, they want to know whether the company truly has control over:
- the substances used in its products or processes;
- supplier and subcontractor documentation;
- consistency between SDSs, composition, and declarations;
- the possible presence of substances of concern;
- the ability to provide precise answers for each product code or part number.
This is where the difference becomes clear between companies that merely have documents and those that have a truly robust regulatory management system.
Chemicals Consulting’s services for SVHC and REACH compliance
Our service is designed to transform complex requests into a structured, traceable, and technically sound process for companies that receive detailed requests from customers in the defense, aerospace, or other highly regulated sectors.
We begin with a training session on SVHCs, REACH authorization, and restrictions, helping to bring together the people within the company who are responsible for managing these issues and ensuring they understand the specific obligations that apply.
We then proceed with an in-depth analysis of the substances relevant to the company, such as chromium compounds, nonylphenol ethoxylates, or other substances of concern, in order to determine whether the issue relates to the Candidate List, authorization, restriction, or other compliance matters.
We then move into the operational phase by reviewing the documentation and requests received from the customer to determine exactly what is being asked, the level of detail required, and the type of evidence needed to respond appropriately.
To support all of this, we also review and verify SDSs for products already in the company database and for new products, in order to assess the consistency of the supporting documentation.
Finally, we assist the company in completing the declarations required by the customer, providing detailed information on the relevant part numbers or products, and we offer a proactive regulatory update service regarding monitored or relevant substances.
Properly managing SVHC-related issues helps reduce the risk of inaccurate responses, disputes, follow-up requests, and business disruptions. Above all, it helps the company present itself to customers as a reliable, knowledgeable, and well-organized supplier.
If your company receives inquiries regarding SVHCs, the Candidate List, authorization, or REACH compliance from customers in the defense, aerospace, or other technically complex supply chains, we can help you review the documentation, clarify key issues, and develop well-founded and consistent responses.
