Key takeaway
What This Development Means
The inclusion of three new substances on the REACH Candidate List underscores ECHA’s commitment to regulating hazardous chemicals. The update carries serious legal and operational implications across sectors. Timely compliance will be critical to avoiding penalties and maintaining market access.
What does inclusion on the REACH Candidate List mean for my business?
It triggers legal obligations including customer notifications, article notifications to ECHA, and safety data sheet updates. Non-compliance can lead to penalties or loss of market access.
How do I know if my products contain these new SVHCs?
Start by reviewing material safety data sheets and supplier declarations. If any substances match the updated SVHC list, conduct a concentration assessment to determine if notification or communication is required.
Source basis: https://echa.europa.eu/-/echa-adds-three-hazardous-chemicals-to-the-candidate-list
On 25 June 2025, the European Chemicals Agency (ECHA) updated the REACH Candidate List by adding three new substances of very high concern (SVHCs). The update increases the list to 250 entries and imposes new legal obligations on companies handling these substances in products, mixtures, or articles across the EU and EEA. The substances include two that are very persistent and very bioaccumulative (vPvB) and one that is toxic to reproduction.
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
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