The requirement to communicate Substances of Very High Concern (SVHC) in articles is part of Article 33 of the EU REACH Regulation. Substances that are Candidates for Authorization on EU REACH are required to be declared to customers if above 0.1% in any component in a product. They must also be declared in the EU SCIP database.

The REACH SVHC list of substances is updated at least twice a year (roughly June and December) in a regularized process involving public consultation and vote by the  EU Member State Committee (MSC).

Common REACH SVHCs in products are Pb, TPP, TBBPA, D6 siloxane, and UV-328.

For an in-depth overview of REACH SVHC, see Claigan’s Ultimate Primer for EU REACH SVHC.

Substances are restricted under Article 67 of the EU REACH Regulation. The REACH restrictions are by substance (or substance family) and are often application specific or include specific derogations (exemptions) if the substance is broadly restricted.  

Examples of high risk substances restricted under REACH in articles are Pb, DEHP, Ni in prolonged human contact, and PFNA.

The Substances of Concern In Products (SCIP) database is the mandatory EU database under the Waste Framework Directive (WFD) for submitting products with SVHCs, the SVHCs in those products, the location of those SVHCs, and their related safe use instructions.

Products in the SCIP database can be uploaded manually or via automated software. Unfortunately, the automated software uploads can create data ‘spam’. The data ‘spam’ caused by automated systems is due to lack of oversight of the data and the magnitude of unreviewed data that a software program can create. Typical errors generated are large amounts of unusable data, and misreporting of SVHCs that are not normally present over 1,000 ppm (such as BPA and MHHPA)

When uploading to the database, manual upload is recommended from data that has been reviewed.

For an in-depth overview of the SCIP database see Claigan’s webinar SCIP Database Goes Live

The EU Persistent Organic Pollutant (POP) Regulation is the ‘recast’ version of the original EU POP regulation. The EU POP regulation regulated (primarily through restriction) in chemicals and articles (physical products) that are persistent in the environment.  

The majority of substances in the EU POP regulation are from the

UN Stockholm Convention on Persistent Organic Pollutants. Persistent Organic Pollutants are chemicals that are not necessarily toxic initially, but can accumulate and persist in the environment to the point that they pose a risk to the human health or the environment.

Common POP substances found in products are PFOA in water resistant fabrics, SCCPs in phthalate plasticized PVC, Dechlorane Plus in transformer wrap, and UV-328 in LCD polarizers.

For a review of upcoming POP substances see Claigan’s webinar – Restricted Materials in 2026.

California Proposition 65 ( Prop 65) requires companies to provide warnings if their products or facilities expose consumers, workers, or the environment above exposure limits to Prop 65 listed chemicals.

The unique aspect of Prop 65 is that Prop 65 offenses can be enforced directly by private citizens (law firms in practice) through civil litigation ( Prop 65 Notices). This unique aspect results in over three hundred (300+) non-compliance notices per month.

Prop 65 warnings are going through a significant change in 2028. Generic warnings will no longer be allowed. Even short form warnings will require declaration of at least one applicable carcinogen and one applicable reproductive toxin.

For a detailed explanation of Prop 65, see Claigan’s in depth lunch & learn – Prop 65 in a Nutshell.

The Canadian Prohibition of Certain Toxic Substances Regulations is the substance restriction component of the Canadian Environmental Protection Act ( CEPA). These Regulations prohibit certain toxic substances in chemicals and articles (manufactured items) with some limited exemptions.

Most of the substances originate from the UN Stockholm Convention on Persistent Organic Pollutants and the Prohibitions have similarity in regulation to the EU POP Regulation and Australia IChEMS. However, the timelines, specifics, and exemptions can be different from similar regulations.

The key substances regulated in the Canadian Prohibition applicable to articles (physical products) are short chain chlorinated paraffins (SCCPs) – known as short chain chlorinated alkanes in Canada.

The Australia Industrial Chemicals Environmental Management Standard (IChEMS) is the primary instrument for regulated substances in chemicals and products.

Similar to the EU POP Regulation and the Canadian Prohibition of Certain Toxic Substances regulation, substances regulated under IChEMS primarily originate from the UN Stockholm Convention on Persistent Organic Pollutants.

The IChEMS regulations include a range of measures including restriction and notification. Substances exempted under an IChEMS restriction commonly have notification to customers and authority requirements instead (Example – Schedule 6 listing of DBDPE).

The key substances regulated in articles under IChEMS are the flame retardants Dechlorane Plus and DBDPE, the UV stabilizer UV-328, SCCPs, and PFOA.

The Canadian Federal Plastics Registry (“Plastics Registry”) is a Section 46 notice under the Canadian Environmental Protection Act (CEPA). The Plastics Registry requires importers, manufacturers, and generators of plastics packaging, plastic products, and plastics waste to report quantities of each plastic annually.

Plastic products include electronics, apparel, automobiles, specific single use plastics, construction materials, and a range of other product categories. This includes not only reporting of plastics in packaging and products, but also volumes of plastics generated as waste by operations of businesses, schools, industry, and government agencies.  

For a detailed explanation of the Canadian Plastics Registry, see Claigan’s webinar – The Fine Details of the Canadian Federal Plastics Registry.