ECHA Adds Three Hazardous Chemicals to REACH Candidate List, Triggering New Compliance Duties

This move under the REACH Regulation (EC No 1907/2006) directly impacts manufacturers, importers, retailers, and downstream users who must assess the presence of these substances in their supply chains and take action to ensure compliance.

What Substances Were Added and Why It Matters

The three newly listed SVHCs are:

• 1,1,1,3,5,5,5-heptamethyl-3-[(trimethylsilyl)oxy]trisiloxane (EC: 241-867-7, CAS: 17928-28-8)
• Decamethyltetrasiloxane (EC: 205-491-7, CAS: 141-62-8)
• Reactive Brown 51 (EC: 466-490-7)

The first two substances are commonly found in cosmetics, personal care items, and automotive care products. They were added due to their vPvB classification under Article 57e. The third, a textile dye, was identified as toxic for reproduction under Article 57c.

These classifications mean the substances pose long-term environmental or health risks, prompting regulatory action under REACH to protect human health and the environment.

Compliance Requirements and Deadlines

From the date of inclusion (25 June 2025), companies have six months to notify ECHA if any of their articles contain these SVHCs above 0.1% weight by weight. This includes notification to the SCIP database under the Waste Framework Directive and updating safety data sheets for mixtures containing the substances.

Additionally, suppliers must inform customers and consumers of the presence of these SVHCs and provide guidance on their safe use. Products containing SVHCs are also ineligible for the EU Ecolabel, affecting marketing and green certification prospects.

Who Is Affected and How to Respond

While chemical manufacturers are the most directly impacted, the update has wider implications across the value chain—including automotive suppliers, cosmetics brands, retailers, and logistics providers.

Affected companies should act swiftly by:

• Reviewing chemical inventories
• Conducting supply chain checks
• Updating product documentation
• Notifying ECHA as required