EU chemicals · REACH Art 33 + SCIP
REACH Article 33, SCIP, or both?
An article containing a Candidate List substance of very high concern above 0.1% w/w can trigger two separate duties. Answer three questions and find out whether you owe REACH Article 33 communication, the SCIP notification to ECHA, or both.
The rule, in one line
If an article you supply on the EU market contains a Candidate List SVHC above 0.1% weight by weight, REACH Article 33 requires you to give recipients — and consumers on request, within 45 days, free of charge — enough information for safe use, at least the substance name. Separately, since 5 January 2021 you must also notify the article to ECHA's SCIP database — unless you are an EU retailer supplying directly and exclusively to consumers and are not an importer, in which case SCIP does not apply but Article 33 still does.
Official sources: ECHA — Candidate List obligations · ECHA — SCIP · ECHA — Notification of substances in articles
SVHC duty verdict
Both — Article 33 + SCIP
You owe both the REACH Article 33 safe-use communication and the SCIP notification to ECHA. See the two duties below.
REACH Article 33 — communicate safe-use information
Give recipients of the article, and consumers on request (within 45 days, free of charge), sufficient information for safe use — at least the name of the SVHC.
SCIP notification — notify ECHA
Submit information on the article to ECHA's SCIP database, so the data is available throughout the product's lifecycle including the waste stage.
Per-article memo
SVHC duty memo (PDF) · €29
A print-ready pack for one article: which duties apply, the Article 33 communication content, the SCIP notification scope, the retailer exemption, and source links — for your compliance file.
This is guidance, not legal advice. The export restates the duties for your inputs; it does not check the Candidate List or determine concentrations.
What this tool is — and isn't
This checker resolves which SVHC duties (REACH Article 33 and/or SCIP) apply from the facts you enter, using ECHA + EUR-Lex guidance. It is an estimate and orientation, not legal advice, and it does not check the Candidate List for you, determine concentrations, or cover separate Article 7(2) notification of substances in articles. Verify against the linked official sources.
How the determination works
1. Is there an SVHC above 0.1%?
The duties only bite if your article contains a Candidate List substance of very high concern above 0.1% weight by weight. The tool asks you — it does not check the list for you.
2. Article 33 communication
If you supply the article on the EU market, Article 33 requires you to pass safe-use information (at least the substance name) to recipients, and to consumers on request within 45 days, free of charge.
3. SCIP notification + the retailer exemption
On top of Article 33, you must notify the article to ECHA's SCIP database — unless you are an EU retailer supplying directly and exclusively to consumers and not an importer, in which case SCIP does not apply but Article 33 still does.
Frequently asked questions
- What is the 0.1% threshold?
- Both duties bite when a Candidate List SVHC is present in the article above 0.1% weight by weight (w/w). Below that, these provisions are not triggered.
- What does Article 33 require?
- Sufficient information to allow safe use of the article — at least the name of the SVHC — to recipients, and to consumers on request within 45 days, free of charge.
- What is SCIP?
- The Substances of Concern In articles database at ECHA. Suppliers placing articles with SVHCs above 0.1% w/w on the EU market notify SCIP so the information is available across the product's lifecycle, including waste.
- I'm a shop selling only to consumers — do I notify SCIP?
- No, if you supply directly and exclusively to consumers and are not an importer, the SCIP retailer exemption applies. But REACH Article 33 still requires you to give consumers the safe-use information on request.
- Since when is SCIP mandatory?
- SCIP notifications have been required since 5 January 2021, under the Waste Framework Directive.
- Is this legal advice?
- No. This tool resolves which duties apply from your inputs. It is orientation, not legal advice, and does not check the Candidate List or determine concentrations. Verify against the linked official sources.