SVHC Notification to ECHA and SCIP When It Applies and What Proof Counts

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A single part containing a Substance of Very High Concern above 0.1% w/w can trigger three separate EU obligations at the same time, and manufacturers that treat them as one requirement carry real regulatory exposure. REACH Article 33 communication, the REACH Article 7(2) notification to ECHA, and the SCIP submission under the Waste Framework Directive each have different triggers, thresholds, and deadlines. Getting the distinction wrong means either over-reporting or missing a filing that surfaces during a customer audit or a Member State inspection. The cost is not only penalty exposure. It is the labor of chasing supplier paperwork that proves nothing, because a blanket “REACH compliant” statement names no substance, no concentration, and no part.

This breakdown of when to notify ECHA about an SVHC separates the three duties, explains how the 0.1% threshold is assessed at the component level, and defines what supplier documentation counts as valid proof. It also shows why one-time data collection fails once the Candidate List is updated, and how BOM-level SVHC tracking and automated supplier data collection keep evidence audit-ready as the list evolves. Certivo, an AI-native compliance platform and system of record, supports this through CORA-powered regulatory intelligence that flags affected parts when new substances are listed. For the underlying rules, see Certivo’s REACH compliance framework and its materials and environmental compliance solution.

Read the full analysis to map your SVHC and SCIP obligations : https://www.certivo.com/blog-details/when-to-notify-echa-or-scip-about-an-svhc-and-what-proof-counts

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