DEFINITION
Article 33 of REACH obliges suppliers to provide sufficient information for safe use when SVHC concentrations in articles are ≥0.1% w/w. Commercial recipients must be informed proactively; consumers are entitled to receive this information free of charge within 45 days upon request.
DeclarationArticle 33 REACH
Article 33 of the REACH Regulation governs the duty to communicate information on substances of very high concern (SVHCs) on the Candidate List in articles and is a central element of supply chain communication in chemical management. The 0.1% threshold (weight by weight) applies to each individual article – not to the overall complex product. If an SVHC exceeds this concentration, the supplier must provide sufficient information to allow safe use of the article, or as a minimum, state the name of the substance.
Furthermore, under certain conditions, notification pursuant to Article 7(2) of REACH may be required, and since 2021, a SCIP notification (Substances of Concern In articles as such or in complex objects [Products]) must be submitted to ECHA.
Strategic Guidelines for Business Operations:
- Maintain an up-to-date inventory of all SVHCs mapped directly to bills of materials (BOMs) and material data
- Systematically document the 0.1% threshold evaluation per individual article
- Establish standardised response packages for industrial/professional clients (B2B) and consumers
- Integrate Article 33 obligations directly into procurement, PLM (Product Lifecycle Management), and quality management systems
- Concurrently assess notification and SCIP reporting duties upon identification of any SVHC
Compliance with Article 33 of REACH is not only a statutory requirement but also a distinct competitive advantage: transparency regarding SVHCs fosters trust within the supply chain and enables proactive compliance management in response to an evolving Candidate List.
Key Points
- The 0.1% w/w threshold applies to the individual article, not the finished product as a whole.
- Proactive communication to commercial customers is mandatory.
- Consumers must receive the requested information within 45 days of their enquiry.
- Alongside Article 33, Article 7(2) notification and SCIP notification obligations must be assessed.
- The Candidate List (SVHC list) is updated regularly – continuous monitoring is required.
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