Table of Contents
The European Chemicals Agency (ECHA) just dropped its latest update to the REACH Candidate List of Substances of Very High Concern (SVHCs) — and the numbers keep climbing.
As of 25 June 2025, the list now holds 250 entries after three more chemicals were added. (Official ECHA Notice →)
That’s not trivia. Each addition rewires what compliance means for manufacturers, importers, and suppliers across the EU. If your materials or components contain even trace amounts of these new SVHCs, your reporting, labeling, and supply-chain communication duties just changed.
The Three New Additions (June 2025)
| Substance | EC / CAS No. | Reason for Inclusion | Example Uses | | -------------------------------------------------------------------- | ----------------------------- | ------------------------------------------------------------- | -------------------------------------------------------------------------- | | 1,1,1,3,5,5,5-Heptamethyl-3-[(trimethylsilyl)oxy]trisiloxane | EC 241-867-7 / CAS 17928-28-8 | Very Persistent and Very Bioaccumulative (vPvB) – Art. 57 (e) | Adhesives, coatings, automotive care, cosmetics and personal care products | | Decamethyltetrasiloxane | EC 205-491-7 / CAS 141-62-8 | vPvB – Art. 57 (e) | Cleaning agents, polishes, waxes, cosmetics | | Reactive Brown 51 (Tetra-sodium/potassium triazine-diazenyl dye) | EC 466-490-7 | Toxic for reproduction – Art. 57 (c) | Textile treatments and industrial dyes |
These aren’t obscure compounds. They’re in coatings, polishes, cosmetics, and dye formulations — the kind of materials that quietly live in global supply chains.
What This Means for Businesses
1. Immediate Legal Obligations
If your articles contain any SVHC above 0.1 % w/w, you must:
- Inform customers and consumers how to use the product safely (REACH Art. 33).
- Notify ECHA within six months of inclusion (so by 25 December 2025) if the article is produced / imported > 1 tonne per year.
- Update Safety Data Sheets (SDS) for substances and mixtures.
- Submit a SCIP notification under the Waste Framework Directive for any SVHC-containing article placed on the EU market.
2. Supply-Chain Visibility Is Non-Negotiable
You can’t comply if you don’t know what’s inside your materials. Send updated questionnaires to suppliers. Demand substance declarations. Build audit trails. If your BOMs still rely on PDF declarations or static spreadsheets, it’s time to automate.
3. Expect Regulatory Escalation
The Candidate List is a gateway to the Authorisation List. Once substances move there, you’ll need explicit EU Commission approval to keep using them. Substitution planning now saves you from redesign crises later.
Compliance Playbook — What You Should Do Next
- Audit your BOMs against the updated SVHC list (250 entries).
- Re-screen materials for the three new entries.
- Engage suppliers — require confirmation of SVHC content > 0.1 %.
- Prepare notifications for ECHA and SCIP as needed.
- Review your disposal and waste streams for SVHC management.
- Identify substitution options now — before authorisation hits.
- Update your internal training so procurement and design teams understand the impact.
Future Implications: Authorisation List
While currently on the Candidate List, it is essential to acknowledge that these substances may be subject to further scrutiny and potential inclusion in the Authorisation List. If a substance is included in this list, its use will be prohibited unless companies apply for authorization and receive approval from the European Commission. Therefore, it is vital for stakeholders to stay informed about regulatory updates and adjust their practices accordingly.
Conclusion
In conclusion, the recent additions to the Candidate List by the ECHA underscore the importance of proactive measures in managing and mitigating the risks associated with hazardous chemicals. By prioritizing safety, compliance, and effective communication, companies can navigate the regulatory landscape, safeguard human health, and protect the environment.
Book a demo with Acquis today our experts will guide you through the process, providing valuable insights and tailored solutions to meet your specific compliance needs.