REACH for SMEs: The Due-Diligence Routine You Cannot Afford to Skip
REACH does not only apply to large manufacturers. Most small chemical suppliers fall into the 'downstream user' category and inherit substantial obligations — including SVHC checks, communication duties, and increasingly, SCIP disclosures. Here is a practical guide.
REACH applies to more companies than most SMEs realise
If your business manufactures, imports, formulates, distributes, or sells chemical products in the European Economic Area — even as a small reseller buying finished products from a large supplier — REACH (Regulation (EC) No 1907/2006) applies to you in some form. The most common confusion is the assumption that REACH is a 'manufacturer's problem.' It is not.
Most SMEs in the chemical value chain qualify as 'downstream users' under Article 3(13). Downstream users do not have to register substances themselves, but they inherit a non-trivial set of duties: respecting the conditions described in extended Safety Data Sheets, communicating new uses upstream, checking for restricted or candidate-list substances, and ensuring their own customer-facing documentation is correct.
A second, increasingly common scenario is the 'only representative' relationship: a non-EU manufacturer designates an EU entity to handle its REACH obligations. If you are an SME importer, you may have an only representative relationship in place without fully understanding what that representative covers — and what it does not.
The three lists every SME should check on every product
Annex XIV (the Authorisation list) contains substances of very high concern that cannot be placed on the EU market or used without a specific authorisation tied to a defined use. The list is relatively short, but the consequences of an Annex XIV substance appearing in a product without authorisation are severe — including immediate withdrawal from the market.
Annex XVII (the Restriction list) contains substances subject to conditions on manufacture, placing on the market, or use. This is where restrictions on substances such as lead in jewellery, cadmium in plastics, formaldehyde in textiles, and many CMR substances in consumer products live. The list is updated frequently; an annual review is the minimum acceptable cadence.
The SVHC Candidate List sits alongside Annex XIV as a 'watchlist' of substances that may eventually be added to authorisation. The list is updated twice a year, typically in January and June. If any candidate-list substance is present above 0.1% w/w in your article or mixture, you have communication obligations to recipients and consumers — and for articles, you have a SCIP notification duty.
The SCIP notification: an obligation many SMEs still miss
Since January 2021, suppliers of articles containing SVHC candidate-list substances above 0.1% w/w must submit a notification to the SCIP database (Substances of Concern In articles, as such or in complex objects (Products)) maintained by ECHA. This obligation flows from the Waste Framework Directive, not REACH itself, and the scope is broad: any 'article' supplied on the EU market is in scope.
Many SMEs incorrectly assume that if their immediate supplier handled SCIP, they are covered. They are not. Each economic operator that supplies an article with an SVHC above threshold has its own SCIP notification duty. The notification is per-article and per-supplier.
Enforcement is uneven across member states but ramping up. Belgium, Germany, France, and the Netherlands have already issued penalties for non-notification. Treating SCIP as optional is no longer a defensible position.
A 30-minute due-diligence routine
For each substance in each formula on your product range: pull the CAS and EC numbers, search the ECHA database for the registration dossier, check the substance against Annex XIV, Annex XVII, and the latest SVHC update (always check the version number and date), and record the result.
Document the date of the check, the version of each list used, the person who performed it, and the conclusion. A short, dated note saying 'SVHC candidate list, version 2026-06, checked against full quantitative composition; no candidate substances above 0.1% threshold' is the difference between 'we assumed it was fine' and 'we did the work.' Auditors care substantially about that difference.
Repeat this routine at every formula change, every supplier change, every SVHC list update (twice a year), and before any new market entry. Embed it in your change-control process so it is impossible to ship a new SKU without it.
Common SME pitfalls
Relying entirely on supplier SDS without independent verification. Supplier SDS are a starting point, not a substitute for your own due diligence — particularly when you reformulate or repack.
Treating the SVHC list as static. The list is updated twice yearly and substances are added, not removed. A product that was clean in 2023 may not be clean in 2026.
Missing the communication chain for articles. Under Article 33 of REACH, recipients of articles containing SVHCs above 0.1% must be informed, and consumers must be informed on request within 45 days.
Confusing tonnage bands. Registration thresholds, communication duties, and chemical safety report requirements all key off tonnage, but the thresholds differ. Misreading one for another can lead to either over- or under-compliance.