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The REACH Candidate List identifies Substances of Very High Concern (SVHCs): chemicals ECHA has determined pose serious risks to human health or the environment. Being on this list isn't a ban. It triggers specific disclosure and notification duties, and it's usually the first visible step toward tighter restriction later. Here's what actually happens when a substance is listed, what criteria get it there, and what changed in the most recent update.
What the Candidate List Actually Triggers
Once a substance is added to the Candidate List, three obligations follow, and they apply at different thresholds:
- Article 33 disclosure: if an article contains the SVHC above 0.1% w/w, suppliers must give downstream customers enough information for safe use. Consumers also have the right to ask suppliers directly whether a product contains a Candidate List substance.
- SCIP notification: if the SVHC exceeds 0.1% w/w and total quantity exceeds 1 tonne per producer or importer per year, a SCIP database notification is required within six months of the substance's listing date.
- Safety data sheet updates: suppliers of the substance itself, or in a mixture, must update the SDS provided to customers.
None of this makes the substance illegal to use. It makes its presence something you have to disclose and, where volume thresholds are met, formally notify. Products containing an SVHC also lose eligibility for the EU Ecolabel, a smaller but real commercial consequence for consumer-facing brands.
The Criteria for SVHC Identification
ECHA identifies a substance as an SVHC based on specific hazard properties:
- Carcinogenicity, mutagenicity, or reproductive toxicity (CMR): the ability to cause cancer, induce genetic mutations, or harm fertility and foetal development
- Persistent, bioaccumulative, and toxic (PBT), or very persistent and very bioaccumulative (vPvB): substances that resist breakdown, accumulate in living organisms, and cause harm
- Endocrine disruptors: substances that interfere with hormone systems in humans or the environment
- Equivalent level of concern (ELOC): a catch-all category for substances causing serious effects comparable to the categories above, even where they don't fit neatly into CMR or PBT criteria
That last category isn't theoretical. In the February 2026 update, ECHA added n-hexane to the Candidate List specifically on ELOC grounds for neurotoxicity, the first substance ever added to the list on this basis rather than the traditional CMR or PBT routes. The same update added bisphenol AF (BPAF) and its salts for established reproductive toxicity.
Candidate List, Authorisation List, and Restriction List Aren't the Same Thing
This is where a lot of confusion happens. Being on the Candidate List is not the same as being restricted or banned:
- Candidate List: triggers disclosure and notification duties, described above. The substance can still be used.
- Authorisation List (Annex XIV): a smaller subset of Candidate List substances that have progressed further. Once a substance is on Annex XIV, it cannot be placed on the EU market or used past its sunset date unless a specific authorisation has been granted, or the use is exempted.
- Restriction List (Annex XVII): a separate mechanism entirely, restricting or banning specific uses regardless of authorisation status.
A substance can sit on the Candidate List for years without ever progressing to Annex XIV. Others move faster. The pace depends on ECHA's prioritisation and the strength of the underlying risk evidence, not a fixed timeline. For the fuller breakdown of how these three lists interact, see our guide to REACH lists explained.
How the List Actually Changes: A Real Example
The Candidate List isn't static, and it doesn't only grow. As of the February 2026 update (the list's 36th revision since REACH came into force), it contains 253 entries. But the same update cycle also shows the list correcting itself in real time:
- Resorcinol remains under active review, with its SVHC identification proposal still marked "identification ongoing" rather than finalised
- 4,4'-methylenediphenol (Bisphenol F, BPF) had its SVHC identification proposal withdrawn before the relevant Member State Committee meeting concluded
This matters for compliance planning: not every substance under discussion ends up listed, and tracking a substance from "registry of intention" through to a confirmed Candidate List entry (or a withdrawal) is a genuinely different task than just checking the current published list once.
What This Means for Your Compliance Process
- Track the list at the update cycle, not annually. ECHA typically revises the Candidate List roughly twice a year, and the six-month SCIP notification clock starts from the listing date, not from when you happen to notice.
- Distinguish "on the Candidate List" from "restricted." Treating every SVHC listing as an immediate ban leads to either panic or, worse, complacency once a team realises the first alarm was overblown. The correct response is disclosure and monitoring, with substitution planning if the substance looks likely to progress toward Annex XIV.
- Watch the registry of intentions, not just the published list. A substance often signals its direction months before formal listing. For newly listed substances, our SVHC Candidate List update guide tracks additions as they're confirmed.
Automate Candidate List Monitoring
Regilient screens your BOM against the current Candidate List automatically, flags articles crossing the 0.1% w/w threshold, and tracks the six-month SCIP notification clock so a listing date doesn't get lost in a spreadsheet.