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EU REACH SVHC and RoHS for exporters: the 0.1% rules explained

Two EU rules decide which chemicals can be in the products you sell to Europe. Under REACH, articles containing more than 0.1 percent of a substance of very high concern (SVHC) from ECHA's Candidate List trigger information and notification duties. Under RoHS, electrical and electronic equipment must stay below limits for 10 restricted substances to carry the CE marking. EU importers pass these duties back to their suppliers, so exporters are asked for test reports and declarations.

Checked against official sources: 2026-10

At a glance

REACH Candidate List253 substances of very high concern (SVHCs) after ECHA added two on 4 February 2026
Threshold in articlesMore than 0.1 percent weight by weight of a Candidate List SVHC
Information dutyEU suppliers must give recipients information for safe use; consumers on request within 45 days
ECHA notificationEU producers and importers notify ECHA if above 0.1 percent and above one tonne per year, within six months of listing
SCIP databaseSince 2021, suppliers of articles with more than 0.1 percent of an SVHC notify ECHA's SCIP database
RoHS substancesLead, mercury, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP and DIBP at 0.1 percent; cadmium at 0.01 percent
RoHS measureLimits apply to each homogeneous material, not to the whole product
RoHS scopeAll electrical and electronic equipment since 22 July 2019, unless specifically excluded

REACH: SVHCs in articles

ECHA's Candidate List names substances of very high concern. On 4 February 2026 it added n-hexane and bisphenol AF and its salts, bringing the list to 253 entries. When an article, such as a garment, a bag, a toy or a device, contains more than 0.1 percent by weight of a listed substance, the EU or EEA supplier must give its customers enough information for safe use, and must answer a consumer's request within 45 days. EU producers and importers must also notify ECHA within six months of a substance's listing if it is above 0.1 percent in their articles and above one tonne per year, and since 2021 suppliers notify such articles to ECHA's SCIP database. Suppliers of the substances themselves, or of mixtures, must give an up-to-date safety data sheet.

RoHS: the 10 restricted substances

What exporters are asked for

Under the RoHS Directive 2011/65/EU, manufacturers carry out the conformity assessment, draw up the EU declaration of conformity and affix the CE marking, and the limits apply to each homogeneous material. Annexes III and IV list exempted applications, some of them time-limited, and some product areas, such as military equipment and photovoltaic panels, are excluded. Because the EU importer or brand owner carries these duties, it usually asks a non-EU supplier for RoHS test reports, a declaration of conformity and an SVHC statement listing any Candidate List substances above 0.1 percent.

Step by step

  1. Check whether your product is an article under REACH and whether it is electrical or electronic equipment under RoHS.
  2. Ask your material suppliers for SVHC and RoHS declarations for each component.
  3. Test high-risk materials such as plastics, coatings, solders and cables against the RoHS limits.
  4. Compare your materials with the latest ECHA Candidate List, which is updated regularly.
  5. Give your EU buyer an SVHC statement, RoHS test reports and, for equipment, the EU declaration of conformity.
  6. Recheck after each Candidate List update and when a RoHS exemption you rely on expires.

Documents you usually need

Common problems and how to avoid them

An EU buyer asks for a REACH SVHC declaration.

What to do: Check each material against the current Candidate List and declare any substance above 0.1 percent by weight of the article.

A cable fails the RoHS lead limit.

What to do: Lead is limited to 0.1 percent in each homogeneous material; replace the material or check whether an Annex III exemption applies.

The SVHC statement is out of date.

What to do: ECHA updates the Candidate List regularly, 253 substances since February 2026; reissue the statement after each update.

A plastic part contains phthalates.

What to do: DEHP, BBP, DBP and DIBP are restricted to 0.1 percent each in electrical and electronic equipment since 22 July 2019.

Sources

  1. ECHA expands Candidate List to 253 SVHCs (10 February 2026) SGS
  2. EU RoHS 2 Directive 2011/65/EU ChemSafetyPro
  3. Directive 2011/65/EU (RoHS): contents legislation.gov.uk

Rules change often. This note is practical guidance based on the sources above, not legal advice. Confirm current requirements with the authority, your importer or a licensed customs broker before you ship.

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Common questions

How many substances are on the REACH Candidate List?

253 after ECHA added n-hexane and bisphenol AF on 4 February 2026.

What does the 0.1% rule mean?

If an article contains more than 0.1 percent by weight of a Candidate List SVHC, information, ECHA and SCIP notification duties apply in the EU.

Which substances does RoHS restrict?

Lead, mercury, cadmium, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP and DIBP: 10 substances.

Is the RoHS limit for the whole product?

No, it applies to each homogeneous material in the product.

Does RoHS need CE marking?

Yes, manufacturers carry out the conformity assessment, issue the EU declaration of conformity and affix the CE marking.

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