EU REACH Understanding the Difference Between Candidate List of SVHCs, Annex XIV, and Annex XVII

TL;DR (for busy compliance owners) EU REACH: Candidate List (SVHC), Annex XIV (Authorisation) & Annex XVII (Restrictions)

• Candidate List (SVHC) = early warning. Triggers supply-chain disclosure (Art. 33) within 45 days and often SCIP reporting; may also trigger Article 7(2) notification within 6 months of inclusion. As of 25 June 2025 the list stands at 250 entries.
• Annex XIV (Authorisation List) = endgame for uses. After the sunset date, you must not use/place on market without an authorisation decision (or the use is exempt). Each entry lists a Latest Application Date and Sunset Date.
• Annex XVII (Restriction List) = hard rules on placing on the market and/or use (think content limits, use bans, emissions caps). As of 19 June 2025, Annex XVII contains 77 entries. Recent big ones: formaldehyde emissions (new Entry 77) and lead in PVC (expanded Entry 63; effective dates running from 29 Nov 2024).

Comparison Table: REACH Candidate, Authorisation & Restriction Lists

What is the REACH Candidate List (SVHC)? : What it is, what it triggers, and why you should act early

The Candidate List of Substances of Very High Concern (SVHCs) is ECHA’s roster of chemicals that meet Article 57 criteria (CMR, PBT/vPvB, or equivalent concern) and are candidates for Annex XIV. ECHA updates the list periodically; on 25 June 2025 it added three more chemicals, bringing the total to 250.

Why you should care: Candidate List inclusion immediately triggers legal obligations even before any future authorisation or restriction.

Immediate duties when your articles contain an SVHC ≥0.1% w/w

• Article 33 communication (supply chain & consumers):

  • To professional recipients: provide “sufficient information to allow safe use,” at a minimum the SVHC name.
  • To consumers on request: provide the same, free of charge within 45 days. Legal text: Article 33 REACH.

• Article 7(2) notification to ECHA (for articles): Producers/importers must notify ECHA within six months of SVHC inclusion in the Candidate List if both are true: (i) SVHC ≥0.1% w/w in the article; and (ii) total quantity of that SVHC in all such articles >1 tonne/year per producer/importer. There are exemptions (e.g., exposure can be excluded; or the use is already registered for that specific use).

• SCIP notification (Waste Framework Directive, from 5 Jan 2021): EU/EEA suppliers of articles containing SVHC ≥0.1% w/w must submit a SCIP dossier (Substances of Concern In Products) to ECHA. The duty is independent of tonnage and exists to support the waste stage.

• Complex objects rule (0.1% applies per component article): The CJEU ruled in C-106/14 that the 0.1% threshold applies at each article level within complex products. Don’t dilute across assemblies. Build your BOM and analytics accordingly.

“What changed lately in 2025?”

• June 25, 2025 update: ECHA increased the Candidate List to **250 entries**. If any newly added SVHCs are in your scope, Article 7(2) notifications are due within six months of that date and Article 33/SCIP obligations continue to apply.

What is Annex XIV (Authorisation) List: When continued use becomes a privilege, not a right

Annex XIV (Authorisation List) contains SVHCs for which the placing on the market or use is prohibited after the “Sunset Date” unless there is an authorisation covering your specific use or the use is exempt. Each entry specifies: Latest Application Date (LAD) and Sunset Date. Submit your application by the LAD to keep operating pending the decision.

How the REACH Annex XIV authorisation process works (practical view)

• Who applies? EU manufacturers, importers, downstream users—or an Only Representative for non-EU entities. The application covers specific uses.
• What’s inside the dossier? Chemical Safety Report, Analysis of Alternatives, Socio-Economic Analysis, and a Substitution Plan where feasible.
• Evaluation & decision: ECHA’s RAC and SEAC issue opinions; the European Commission makes the final call, often with a review period (e.g., 4–12 years).

Reality check: If you wait until Sunset is near, you will either (a) stop using the substance, (b) scramble for an upstream authorisation to cover you, or (c) file a rushed AfA that’s weak on alternatives, risking short review periods and costly re-submissions.

What Annex XVII (Restrictions) does: Market rules you can’t negotiate

REACH **Annex XVII** sets legally binding restrictions on the manufacture, placing on the market, or use of substances—on their own, in mixtures or in articles. These are non-negotiable conditions (content limits, use bans, sales prohibitions, emissions thresholds) with compliance dates and exemptions baked in.

As of 19 June 2025, Annex XVII contains 77 unique substance entries (several entries aggregate substance groups).

Recent, high-impact restrictions you should already be tracking

• Formaldehyde & formaldehyde releasers (Entry 77) new in 2023: Emissions limits apply to articles under defined testing conditions:

  • Furniture & wood-based articles: ≤ 0.062 mg/m³
  • Other articles: ≤ 0.080 mg/m³
  • Road vehicles (interior air): ≤ 0.062 mg/m³ Staggered applicability dates start 6 Aug 2026 (vehicles 6 Aug 2027).

• Lead in PVC (Entry 63 expanded) - 2023 amendment: Lead must not be present ≥0.1% by weight of PVC material in articles; general application date 29 Nov 2024 with specified transitional exemptions (e.g., recovered PVC in certain uses).

These two alone have reshaped bill-of-materials, testing and supplier controls in furnishings, flooring, automotive, electronics housings, wallcoverings, and more. If your compliance program hasn’t accounted for Entry 77 and the PVC lead update, you’re already behind the curve.

How the three regimes connect from Candidate List → Annex XIV or XVII(and how to operationalise them)

• Candidate List is the feeder: substances on it can move to Annex XIV (after prioritisation and Commission decision). For Annex XVII, restrictions can apply to any substance—SVHC or not—through a separate Annex XV restriction process if risk justifies it. Watch ECHA’s Registry of restriction intentions to anticipate Annex XVII changes.

Obligations by product type

Citations: Art. 33, Art. 7(2), SCIP/WFD, Annex XVII scope.

REACH Implementation guide: do this now (no excuses)

Inventory & data model

• Explode complex objects to article level (per CJEU C-106/14). Your data model must support per-component concentrations and supplier declarations.
• Map SVHC presence across your BOM vs. the current Candidate List (250). Use reliable screening + supplier attestations tied to lot/material IDs—not generic “compliant” claims.
• Tag entries impacting you in Annex XVII (77 entries), starting with Entry 77 (formaldehyde) and Entry 63 (lead in PVC) if your categories are in scope. Build a compliance matrix that links entries to parts, materials, and processes.

Workflows & obligations

• Consumer request workflow (Art. 33(2)): Build a 45-day SLA with templated, substance-named responses and safe-use instructions. Track & prove response times. ([EUR-Lex][1])
• Article 7(2) notifications: When a new SVHC hits the Candidate List and you meet tonnage + threshold, file within six months—and document your exemption logic if you rely on the “exposure can be excluded” carve-out.
• SCIP submissions: Keep a one-to-many mapping between internal BOM items and SCIP dossiers (reuse IUCLID components where possible). Ensure you propagate SCIP identifiers to downstream partners.
• Annex XIV risk planning: If any use in your chain touches an Annex XIV substance, align with upstream actors to see whether an authorisation exists, is being applied for, or if you must substitute. Do not assume upstream coverage without a documented chain to your exact use.
• Annex XVII testing & certification: For entries like 77 (formaldehyde), establish test protocols aligned to the OJEU appendix methods and make sure labs are applying the correct reference conditions. For lead in PVC, adjust incoming QC to verify ≤0.1% and manage carve-outs (e.g., recovered PVC) with documented evidence and date-based controls.

REACH Regulation Governance & monitoring

• Track regulatory change via:

  • ECHA news & list pages (Candidate List, Authorisation List, Restrictions index).
  • Registry of restriction intentions (PFAS and other families).

• Set “event” triggers:

  • On Candidate List update → auto-screen materials; open Article 7(2) eligibility checks; start SCIP deltas.
  • Before Annex XVII applicability date → lock product changes, pull-forward inventory decisions, and update labeling/claims.

The letter of the law for REACH (so you can cite it internally)

• Article 33 REACH—duty to communicate; 45-day consumer response requirement. (See EUR-Lex consolidated text.)
• Article 7(2) REACH—six-month notification to ECHA for SVHCs in articles (when ≥0.1% and >1 t/y). (ECHA’s official page explains the trigger and deadline.)
• SCIP obligation—arises from the Waste Framework Directive; ECHA hosts the SCIP system and support.
• Annex XIV (Authorisation List)—LAD and Sunset date per substance listed on ECHA’s page.
• Annex XVII (Restrictions)—official index and updates. Formaldehyde Entry 77 (Reg. 2023/1464) and Lead in PVC (Reg. 2023/923).
• CJEU C-106/14—“once an article, always an article” threshold interpretation.

Practical examples Complying with REACH regulation (to make this concrete)

Example A: Furniture OEM (wood panels, foam, adhesives)

• Formaldehyde Entry 77: you must ensure emissions ≤0.062 mg/m³ for furniture/wood-based articles by 6 Aug 2026 (method: Appendix 14 to the Regulation). Update supplier specs, qualify alternative resins, and plan lab testing cadence for design/material changes.
• SVHC exposure: check edge-banding, coatings, adhesives for SVHCs (e.g., certain phthalates or solvents) ≥0.1%. If any, you owe Article 33 disclosures and SCIP filings; Article 7(2) applies if your tonnage crosses 1 t/y.

Example B: Cable & enclosure supplier (PVC heavy)

• Lead in PVC (Entry 63 expansion): enforce ≤0.1% lead in PVC from 29 Nov 2024; document any applicable recovered-PVC exemptions and their time limits. Tighten incoming material CoAs, and re-qualify stabiliser systems with suppliers.
• Candidate List vigilance: if any newly listed SVHCs appear in plasticisers or pigments, your Art. 33, SCIP, and possibly Art. 7(2) obligations kick in.

What “good REACH Regulation Setup ” looks like (maturity model) for Compliance Professionals

1. Basic: Spreadsheet inventory, ad-hoc supplier letters, manual replies to consumer requests.
2. Managed: Article-level BOM with SVHC flags, templates for Art. 33 responses, basic SCIP capability, tracked Annex XVII applicability dates.
3. Advanced: Automated screening against live Candidate List; rule engine for Art. 7(2) eligibility; integrated SCIP publishing; change-control gates tied to Annex XVII entries; proactive Annex XIV strategy (substitution roadmap vs authorisation).
4. Best-in-class: Knowledge graph of regulations → materials → parts → uses; vectorised retrieval against your tech docs and CoAs; auto-generated customer disclosures per SKU & market; dashboard for next 6–18 months of regulatory impact.

Final Thoughts: Stay Ahead of REACH Compliance

Understanding the REACH Candidate List, Authorisation List, and Restriction List isn’t optional—it’s essential for businesses operating in or selling to the EU market. Staying proactive helps avoid penalties, protects your supply chain, and enhances corporate sustainability efforts.

Need help ensuring REACH compliance? Our regulatory specialists can guide you. Schedule a Compliance Consultation today.