REACH SVHC 2026 — buyers checklist for China-sourced chemistry

Q: How often is the SVHC list updated?

Twice a year — typically a January and a June batch. ECHA publishes the candidate proposals 6-9 months ahead.

Q: Do I need to declare SVHC presence to my own customers?

Yes, under Article 33(1) you must inform downstream users of any SVHC > 0.1% w/w in articles you supply, within 45 days.

EU buyers' compliance checklist for the 2026 SVHC additions — what to ask, what to demand in the SDS, and how to validate a Chinese exporter's REACH dossier holds up.

What's new in the 2026 SVHC list

ECHA added 8 substances to the Candidate List in the 25 January 2026 round, taking the total to 251. Three are heavily used in Chinese chemistry exports and worth flagging in your supplier audits:

Diphenyl(2,4,6-trimethylbenzoyl)phosphine oxide (TPO) — used in UV cure systems
2-Ethylhexanoic acid and its salts — plasticisers / metal driers
N,N-dimethyl-p-toluidine — radical accelerator in dental composites

Buyer checklist

1. Ask the right SDS questions

Section 2: does the SDS list every 2026 SVHC > 0.1% w/w?
Section 15: which member-state authorisation regime applies?
Section 16: is the SDS version dated 2026 or later?

2. Validate the REACH dossier

Pull the registration number from the SDS, query ECHA's public registry — does the registered tonnage band cover your annual buy?
Ask for the Lead Registrant SIEF letter (most legit registrations have one).

3. Demand a duty-of-information letter

Article 33(1) requires suppliers to inform you of SVHC presence

> 0.1% within 45 days. Get this in writing per shipment, not > just per supplier.

4. Cross-check against your downstream-user IUCLID

Your registered uses must cover what you actually do; if a Chinese-made SVHC arrives in a use-case the registrant didn't register, that's a Chemical Safety Report obligation back on you.

Red flags to walk away from

SDS dated before 2026-01-25 (won't include the new SVHC entries)
Registration number that doesn't resolve on echa.europa.eu
Tonnage band on the registration < your annual buy
"Mixture" registrations citing only the substance class, not the CAS-specific entries

Frequently asked

How often is the SVHC list updated?

Twice a year — typically a January and a June batch. ECHA publishes the candidate proposals 6-9 months ahead.

Do I need to declare SVHC presence to my own customers?

Yes, under Article 33(1) you must inform downstream users of any SVHC > 0.1% w/w in articles you supply, within 45 days.

Can a Chinese supplier register REACH directly?

No — non-EU manufacturers register through an EU-based Only Representative (OR). Always confirm the OR's name and contact in Section 15 of the SDS.