1. Regulatory outlook: What businesses need to know
The European Chemicals Agency (ECHA) currently anticipates that the next update to the REACH Candidate List of Substances of Very High Concern (SVHCs) will take place in June 2027.
The Candidate List is an important part of the European Union’s chemicals regulatory framework. The inclusion of a substance can trigger specific obligations for companies manufacturing, importing or supplying substances, mixtures and articles within the scope of the REACH Regulation (EC) No 1907/2006.
As the next anticipated update approaches, businesses should use this period to review their existing compliance arrangements, strengthen supplier communication and identify substances that may be relevant to their products and supply chains.
Important: June 2027 is the current anticipated timing, not a confirmed publication date. Companies should continue monitoring official ECHA announcements for changes to the regulatory schedule.
2. Understanding the latest Candidate List position
The Candidate List was last updated on 4 February 2026. The update added two entries:
- n-Hexane (EC 203-777-6; CAS 110-54-3): Identified as a substance of very high concern on the basis of an equivalent level of concern regarding human health, under Article 57(f) of REACH.
- Bisphenol AF (BPAF) and its salts: Identified because of their toxic properties for reproduction, under Article 57(c) of REACH.
These additions demonstrate why companies should maintain a substance-level compliance review rather than relying solely on periodic supplier declarations or older regulatory assessments.
The relevance of an entry depends on the substance identity, its presence in the relevant material or product, the company’s role in the supply chain and the applicable legal requirements.
3. Why Candidate List monitoring matters
Candidate List inclusion does not automatically mean that a substance is prohibited. However, it can introduce or affect important information, communication and notification requirements.
Companies should consider the following areas when assessing their compliance position.
Communication obligations for articles
Under Article 33 of REACH, suppliers of articles containing a Candidate List substance above 0.1% weight by weight must provide the recipient with sufficient information available to them to allow safe use of the article, including at least the name of the substance.
Consumers may also request relevant information, which must be provided within 45 days of receipt of the request.
Businesses should therefore establish processes to obtain reliable substance information from suppliers and communicate applicable information to customers.
Notification requirements
Article 7(2) of REACH requires producers or importers of articles to assess whether notification to ECHA is necessary where a Candidate List substance is present above 0.1% weight by weight and the total quantity of that substance in the relevant articles exceeds one tonne per year per producer or importer.
The applicable exemptions and other conditions under Article 7 must also be considered. The concentration threshold alone does not determine whether notification is required.
SCIP database considerations
Under the EU Waste Framework Directive, information may need to be submitted to the SCIP database for articles containing Candidate List SVHCs above 0.1% weight by weight, where the relevant requirements apply.
Companies should evaluate their role, product scope and reporting responsibilities and maintain appropriate supporting information.
Safety Data Sheets and supply-chain communication
Where applicable, companies should review Safety Data Sheets (SDS), substance declarations, product specifications and other compliance documents following changes to a substance’s regulatory status.
The need for an SDS update depends on the applicable legal requirements and the substance or mixture concerned. Candidate List inclusion alone does not mean that every SDS must automatically be revised.
4. Recommended preparation before the next update
Pharmegic recommends that businesses take a proactive approach instead of waiting for the anticipated 2027 update.
Review the substance inventory. Compare substances used in manufacturing, imported products and relevant materials against the current official Candidate List. Ensure that substance identities, EC numbers and CAS numbers are checked carefully.
Obtain updated supplier information. Request current declarations from raw material suppliers and relevant component manufacturers. Where necessary, clarify whether declarations cover individual substances, mixtures, components or finished articles.
Assess applicable legal obligations. Determine whether Article 7 notification, Article 33 communication or SCIP-related requirements apply to the company’s specific activities and products.
Identify regulatory information gaps. Review missing substance composition data, outdated declarations and inconsistencies between SDS information and supplier documentation. Prioritise gaps according to product relevance and regulatory exposure.
Establish a monitoring process. Track ECHA announcements, SVHC intentions, public consultations and Candidate List revisions. Assign responsibility for assessing new developments and communicating relevant changes internally and across the supply chain.
5. Candidate List inclusion versus future regulatory proposals
Businesses should distinguish between a substance that is already included on the Candidate List and one that is only subject to an intention, consultation or proposed regulatory action.
A substance under consideration is not automatically a confirmed Candidate List entry. Its eventual regulatory status depends on the applicable assessment and decision-making process.
Similarly, inclusion on the Candidate List and inclusion in Annex XIV of REACH, the Authorisation List, are separate regulatory steps with different implications.
Companies should base compliance decisions on the substance’s actual status in the relevant official ECHA list and the applicable legal provisions, rather than treating a planned or proposed action as a final decision.
6. How Pharmegic Healthcare Limited can support your compliance activities
Pharmegic Healthcare Limited supports companies with EU REACH regulatory compliance and related chemical regulatory activities.
Our services include:
- EU REACH registration support and Only Representative services for eligible non-EU manufacturers.
- Regulatory dossier preparation and updates using IUCLID.
- SDS preparation and review in accordance with applicable requirements.
- SVHC and Candidate List screening support.
- Review of supplier declarations and regulatory documentation.
- Regulatory monitoring and guidance on applicable REACH obligations.
The scope of support depends on the substance, the company’s role in the supply chain and the specific regulatory requirements involved.
