REACH & SCIP — Chemical Substances Regulation
The EU's chemicals regulation framework and SCIP database — how SVHC disclosure feeds directly into Digital Product Passport requirements under ESPR.
Overview
REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) is the EU's comprehensive chemicals regulation. Together with the SCIP database, it forms the foundation for substance-of-concern data that feeds directly into Digital Product Passports.
Legal basis
- Adopted: 18 December 2006
- In force: 1 June 2007
- SCIP obligation: 5 January 2021 (under Waste Framework Directive Article 9)
- Administered by: European Chemicals Agency (ECHA)
Why REACH matters for DPP
ESPR requires disclosure of Substances of Very High Concern (SVHCs) present above 0.1% by weight in products. The SVHC Candidate List is maintained under REACH — making REACH compliance directly linked to DPP requirements.
Companies that already maintain SCIP compliance workflows have a significant head start on DPP substance data.
The SVHC Candidate List
- Currently contains 251 substances (as of November 2025)
- Updated twice yearly (January and June)
- Includes carcinogens, mutagens, reproductive toxins, persistent bioaccumulative toxins, endocrine disruptors
| Update | Date | Substances added | Total | |--------|------|-----------------|-------| | 32nd | January 2025 | 5 (+1 updated) | 247 | | 33rd | June 2025 | 3 | 250 | | 34th | November 2025 | 1 | 251 |
SCIP database
The SCIP (Substances of Concern In Products) database is managed by ECHA under the Waste Framework Directive:
- Mandatory since: 5 January 2021
- Suppliers of articles containing SVHCs above 0.1% w/w placed on the EU market must submit to SCIP
- Required data: article type, component identifiers, SVHC name/CAS number, concentration range, safe use instructions
- Data is publicly accessible to waste operators for end-of-life handling
Integration with Digital Product Passports
SCIP data maps directly to DPP requirements under ESPR:
- ESPR Article 9 requires disclosure of "substances of concern" — same data as SVHC notifications
- SCIP notifications become a data source/feed for DPP substance disclosure fields
- IPC-1752B standard (used by ~97% of SCIP notifications) supports DPP data fields
- Full Material Disclosure (FMD) strategies align with both SCIP and DPP requirements
Key obligations
- Registration of substances manufactured/imported above 1 tonne/year
- Communication of SVHC presence in articles to recipients (Article 33)
- SCIP notification to ECHA when SVHCs are present above 0.1% w/w
- Authorisation required for use of Annex XIV substances
- Consumer information within 45 days of request
REACH recast — upcoming
A REACH Recast (targeted revision) has been discussed, though no formal proposal had been published as of March 2026. Anticipated changes, if a recast proceeds, may include:
- Simplified registration process
- Updated SVHC provisions aligned with ESPR/DPP
- Enhanced digital information requirements (machine-readable chemical data)
- Better integration with SCIP database
These remain anticipated changes only and are subject to the Commission's legislative programme.
Penalties
REACH penalties are set at member state level and vary significantly by jurisdiction and severity of violation:
- Germany: Maximum €50,000 for Art. 33 non-compliance — failure to disclose SVHC presence to B2B supply chain customers within 45 days of request
- General REACH violations: Administrative fines up to €30,000 and/or up to 4 years imprisonment for registration or authorisation breaches
- Major health-impacting violations: Fines up to €5,000,000 and/or up to 7 years imprisonment in the most serious cases
- Market withdrawal and product recall for non-compliant articles
- Criminal penalties exist in several member states for deliberate or repeated infringement
The 45-day consumer information deadline (Art. 33) is the most commonly triggered obligation for companies placing articles on the EU market.
Who is affected
- Manufacturers of articles containing SVHCs above 0.1% by weight — must notify ECHA via SCIP and inform supply chain customers
- Importers of articles containing SVHCs — same notification obligations apply regardless of whether the SVHC was intentionally added
- Downstream users of chemical substances — subject to authorisation requirements for Annex XIV substances and restriction compliance
- Any company required to create a DPP under ESPR — SVHC data from REACH/SCIP workflows feeds directly into DPP substance disclosure fields (Art. 9 ESPR)
- Companies placing products on the EU market — must respond to consumer SVHC enquiries within 45 days (Art. 33(2))
Key articles
| Article | Subject | |---------|---------| | Art. 33 | Communication duty — suppliers must disclose SVHC presence above 0.1% w/w; consumers may request information within 45 days | | Art. 57–59 | Authorisation — SVHCs on Annex XIV cannot be used without explicit Commission authorisation | | Art. 67 | Restrictions — Annex XVII prohibitions and conditions on manufacture, use, and placing on market | | Art. 128 | Penalties — member states must establish effective, proportionate, dissuasive penalties |