What does REACH Article 33 require for SVHCs in articles, and how does the SCIP database notification work: who must notify, what is the 0.1% w/w threshold, what information goes into a SCIP notification and what must suppliers tell customers and consumers?

Approach. I read the current consolidated REACH Regulation (EUR-Lex consolidated version of 11 May 2026) for Articles 3, 7, 33 and 59. I then read national competent authority guidance on Article 33, Article 7(2) and SCIP from Ireland's HSA, Germany's BAuA REACH-CLP-Biozid helpdesk and Belgium's FPS Public Health (AskREACH). None of these sources holds the Waste Framework Directive or ECHA's SCIP documents, so for SCIP I used EUR-Lex and ECHA search results, and I flag below which points rest only on snippets.

1. Which substances and products are in scope

• Article: "an object which during production is given a special shape, surface or design which determines its function to a greater degree than does its chemical composition" (Art. 3(3)) ^[1].
• SVHC: a substance that meets the Article 57 criteria and has been placed on the Candidate List under Article 59(1). ECHA publishes the list and updates it on its website as soon as an inclusion decision is taken (Art. 59(10)) ^[2].

2. Article 33: what you must communicate

Art. 33(1), business customers. Any supplier of an article containing a Candidate List substance above 0.1 % w/w must give the recipient enough of the information it holds to allow safe use of the article. As a minimum, that means the name of the substance ^[3].

• A "supplier of an article" is any producer, importer, distributor or other actor in the supply chain who places an article on the market (Art. 3(33)).
• A "recipient of an article" is an industrial or professional user or a distributor. Consumers are excluded (Art. 3(35)) ^[4].
• The duty applies as soon as the substance is added to the Candidate List ^[5].

Art. 33(2), consumers. The same information must be given to a consumer who asks for it, free of charge, within 45 days of receiving the request ^[3].

• BAuA's reading: a supplier only has to answer if the article actually contains a Candidate List substance above 0.1 %, so not replying is not in itself a breach. If a consumer gets no answer or only evasive ones, they can go to the regional enforcement authority once the 45 days have passed ^[6].
• Belgium offers the voluntary AskREACH system and its Scan4Chem app for answering consumer requests. Article 33 itself remains mandatory, and non-compliance in Belgium can lead to criminal sanctions (8 days to 3 years' imprisonment; fines from €160 to €4,000,000, plus surcharges) ^[7].

How the 0.1 % w/w is calculated. The threshold applies to each individual article, not to the assembled product. BAuA's example: the information must relate to a bicycle handle grip, not the whole bicycle, following the CJEU ruling on this point ^[6].

3. Article 7(2) notification to ECHA (separate from SCIP)

Who and when. Producers and importers of articles (not distributors) must notify ECHA when both of these apply ^[8]:

• the Candidate List substance is above 0.1 % w/w in the articles, and
• it totals more than 1 tonne per producer or importer per year.

The deadline is six months after the substance is added to the Candidate List (Art. 7(7)).

Exemptions:

• Exposure to humans or the environment can be excluded under normal and reasonably foreseeable conditions of use, including disposal. In that case the producer or importer must supply instructions to the recipient instead (Art. 7(3)).
• The substance is already registered for that use (Art. 7(6)).

What the notification contains (Art. 7(4)):

• notifier identity and contact details
• registration number(s), if available
• substance identity
• classification
• a brief description of the use(s) of the substance in the article and of the uses of the article
• tonnage range

Notifications go to ECHA through REACH-IT ^[9].

4. SCIP database notification (Waste Framework Directive)

Legal basis and who must notify. Article 9(1)(i) of Directive 2008/98/EC requires Member States to ensure that, from 5 January 2021, any supplier of an article (as defined in REACH) gives ECHA the information required under REACH Article 33(1). This comes from a search snippet of the EUR-Lex consolidated Directive.

• Because the Directive uses the REACH definition, the duty covers producers, importers, distributors and other actors who place articles on the market.
• The trigger is the Article 33(1) trigger: a Candidate List substance above 0.1 % w/w. Article 33(1) contains no 1-tonne condition, unlike Article 7(2).
• The duty applies through national transposing law. In Germany it is § 16f of the Chemicals Act (Chemikaliengesetz), in force from 5 January 2021, and ECHA set up the SCIP database for it ^[10].

What goes into a SCIP notification. This is from search snippets of ECHA's SCIP information requirements documents, so it is a summary rather than the full data model:

• Identifying the article: this can be the article as such or a complex object. It includes names and a primary article identifier such as EAN/GTIN, a catalogue or part number, or an ECHA Article ID.
• Article category: a CN or TARIC code from the EU's TARIC customs tariff list.
• The Candidate List substance: its name, concentration range and location in the article.
• Safe-use information: this includes information to ensure the article is properly managed once it becomes waste.

5. In short: who must tell whom

Duty	Who	Trigger	To whom / deadline
Art. 33(1)	Every supplier of an article	SVHC > 0.1 % w/w per article	Business recipients, on supply; at least the substance name
Art. 33(2)	Every supplier of an article	Same	Consumers, on request; free, within 45 days
Art. 7(2)	EU producers/importers of articles	> 0.1 % w/w and > 1 t/y	ECHA (REACH-IT), within 6 months of Candidate List inclusion
SCIP (WFD Art. 9(1)(i))	Every supplier of an article	Art. 33(1) trigger	ECHA SCIP database, from 5 Jan 2021

The BAuA FAQ lists a question on whether passing on the SCIP number is enough to meet Article 33, or whether the substance name must still be given ^[11]. The answer text wasn't in the record I could read. Article 33 itself says the substance name is the minimum.

Sources:

• EUR-Lex, Directive 2008/98/EC consolidated (2025-10-16)
• ECHA, Requirements for SCIP notifications (Oct 2020)
• ECHA, Detailed information requirements for the SCIP database (Sept 2019)