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REACH
On February 4, 2026, the European Chemicals Agency (ECHA) added two more substances to the Candidate List of Substances of Very High Concern (SVHC). With this update, the list now contains 253 entries.
The inclusion of new substances immediately entails various legal obligations for companies. This article summarizes which substances are affected and what measures are now necessary.
Which substances have been newly added?
The two substances newly added to the candidate list are:
1. n-Hexane
Reason: specific organotoxicity with repeated exposure
Examples of uses: formulations, polymer processing, coatings, cleaning agents
2. 4,4′-[2,2,2-trifluoro-1-(trifluoromethyl)ethylidene]diphenol (bisphenol AF) and its salts
Reason: toxic to reproduction
Examples of uses: process regulators, cross-linking additives
Inclusion does not mean an immediate ban on use, but it does trigger immediate binding REACH and SCIP obligations.
REACH obligations that now apply
As soon as a substance is included in the Candidate List, companies that use it as a substance, in mixtures, or in articles are immediately subject to the following obligations:
1. Duty to provide information under Article 33 of REACH
If an article contains more than 0.1% (w/w) of an SVHC, companies must:
inform their industrial customers immediately about safe use,
respond to consumer inquiries free of charge within 45 days.
This obligation applies to every affected article throughout the entire supply chain.
2. Notification to ECHA (Article 7(2) REACH)
Notification to ECHA is required if:
an SVHC > 0.1% (w/w) is contained in an article and
the manufacturer or importer places more than 1 ton per year of this article on the market.
Notification deadline: within six months, i.e. by August 4, 2026, at the latest.
3. Updating safety data sheets (SDS)
If substances or mixtures contain one of the newly added SVHCs, the following must be done:
Safety data sheets must be updated
and customers must be informed accordingly.
This applies to all EU and EEA suppliers of such substances or mixtures.
SCIP obligations under waste legislation
In parallel to REACH, obligations under the EU Waste Framework Directive also apply:
SCIP notification requirement for > 0.1% SVHC in articles
Any company that manufactures, imports, or distributes an article containing SVHCs above 0.1% (w/w) must submit a SCIP notification to ECHA.
This notification is made to the publicly accessible SCIP database and must be submitted immediately after the relevance is recognized.
Recommended immediate measures
To ensure that companies comply with all legal requirements, a structured approach is recommended:
1. Review product and substance portfolios
Identify the presence of the two new SVHCs
Record concentrations and areas of use
2. Involve suppliers
Request updated substance and article data
Ensure coordination along the supply chain
3. Implement communication obligations
Proactively inform customers in accordance with Article 33
Review processes for consumer requests
4. Submit notifications on time
REACH notification: by August 4, 2026
SCIP notification: immediately after determining relevance
5. Update safety data sheets
Ensure documentation and dissemination of current hazardous substance information
Conclusion
The update of the candidate list by ECHA requires companies to react quickly and analyze data accurately. The new obligations affect numerous industries—from polymer processing and coatings to technical applications with cross-linking additives.
A systematic approach helps to minimize risks and reliably meet all legal requirements.
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