EU REACH for Articles: SVHC, SCIP and Annex XVII Limits

Key takeaways

Under Article 33, an EU supplier of an article containing a Candidate List SVHC above 0.1% w/w must give customers enough information for safe use, at least the substance name, and must answer consumers within 45 days.
Since 5 January 2021, suppliers of such articles in the EU must also send that information to ECHA's SCIP database under the Waste Framework Directive.
Annex XVII restrictions are hard limits. For Indian home goods the most relevant are azo dyes (43), chromium VI in leather (47), nickel release (27), PAHs (50), phthalates (51), CMRs in textiles (72), formaldehyde (77) and PFHxA (79).
Entry 77 limits formaldehyde emissions from furniture and wood-based articles to 0.062 mg/m³ from 6 August 2026.
Compliance is proven by accredited lab tests on the right materials; an inspection checks that the tested materials are the ones in the shipment.

How REACH applies to imported articles

REACH is the EU's main chemicals law. Most of it deals with substances and mixtures, but it also applies to articles: objects whose shape and design matter more than their chemical make-up, such as a chair, a cushion cover, a lamp base or a leather bag.

REACH duties fall on companies in the EU. The EU importer of Indian goods is the one who must comply, so it will ask the Indian supplier for declarations and test reports. Three parts of REACH matter most for articles:

Article 33: passing on information about substances of very high concern (SVHCs) on the Candidate List.
Article 7(2): producers and importers must notify ECHA when a Candidate List substance is above 0.1% w/w in their articles and above one tonne per year in total.
Annex XVII: restrictions that ban or limit specific substances in specific articles.

ECHA adds substances to the Candidate List from time to time, and the duties apply from the date a substance is added. Check the list at the time of each order.

SVHCs, the 0.1% rule and SCIP

Sources: Regulation (EC) 1907/2006, Articles 7 and 33; Directive 2008/98/EC as amended by Directive (EU) 2018/851.
Duty	Trigger	What must be done
Inform business customers (Article 33(1))	Candidate List SVHC above 0.1% w/w in the article	Give enough information for safe use, at least the substance name, with the delivery
Inform consumers on request (Article 33(2))	Same	Reply free of charge within 45 days
Notify ECHA (Article 7(2))	Same, and more than 1 tonne per year of that substance in the importer's articles	Notification to ECHA, in the cases set out in Article 7
SCIP notification (Waste Framework Directive, Article 9(1)(i))	Same as Article 33(1)	Submit the Article 33(1) information to ECHA's SCIP database, since 5 January 2021

The 0.1% is measured against the whole article. For a complex product, such as a sofa with fabric, foam, wood and metal legs, each component article counts separately. The EU Court of Justice confirmed this in case C-106/14 (10 September 2015).

In December 2025 the European Commission proposed, in an environmental simplification package, to remove the SCIP database duty. Until any change is adopted and applies, the SCIP duty remains in force.

Annex XVII restrictions relevant to home goods and textiles

Source: REACH Annex XVII, consolidated text, and Regulation (EU) 2023/1464 (entry 77), reviewed 13 Oct 2026. Exemptions apply; read the full entry.
Entry	Substance	Main limit for articles	Typical Indian products
27	Nickel	Release above 0.5 µg/cm²/week banned in items in direct and prolonged skin contact, such as jewellery, watch parts, and rivets, buttons and zippers on garments	Garments, fashion jewellery, accessories
43	Azo dyes	No dyes releasing listed aromatic amines above 30 mg/kg in textile and leather articles in prolonged skin contact, including bedding, towels, chair covers and yarn and fabric sold to consumers	Dyed cotton, bedding, cushion covers, leather goods
46a	Nonylphenol ethoxylates	Below 0.01% by weight in textiles expected to be washed in water, since 3 February 2021	Garments, home textiles
47	Chromium VI	Below 3 mg/kg of the dry weight of leather in leather articles or leather parts that touch the skin	Leather furniture, bags, footwear, belts
50	PAHs (8 listed)	Not above 1 mg/kg each in rubber or plastic parts in direct and prolonged or repeated skin contact in consumer articles (0.5 mg/kg for toys and childcare articles)	Rubber grips, handles, plastic trims
51	DEHP, DBP, BBP, DIBP	Below 0.1% in total of the plasticised material in articles, since 7 July 2020	PVC or PU leatherette, plastic parts, prints
72	CMR substances (Appendix 12)	Limits per substance in clothing, footwear and textiles with similar skin contact, since 1 November 2020; free formaldehyde 75 mg/kg	Garments, bed linen
77	Formaldehyde	Emission not above 0.062 mg/m³ from furniture and wood-based articles, 0.080 mg/m³ from other articles, in a test chamber, from 6 August 2026	Furniture with MDF, plywood or particleboard; panels
79	PFHxA and related substances	Below 25 ppb (PFHxA and salts) or 1,000 ppb (related substances): consumer clothing textiles from 10 October 2026; other consumer textiles from 10 October 2027	Water-repellent garments, outdoor cushions, home textiles

Entry 77 has exemptions, including articles exclusively for outdoor use and second-hand articles. Entry 72 excludes wall-to-wall carpets, rugs and runners. Entry 61 also bans dimethylfumarate (DMF), a mould inhibitor, above 0.1 mg/kg in any article or part of it.

What this means for goods made in India

REACH risk in Indian supply chains usually comes from bought-in materials rather than the final assembly.

Dyed textiles and leather. Azo dyes and chromium VI depend on the dye house and tannery. Ask which unit dyed or tanned each lot, and test per material and colour.
MDF, plywood and particleboard. Under entry 77 the limit applies to the whole furniture item. Low-emission board and finishes matter, and board substitution during production can break compliance.
PVC and PU leatherette, rubber and plastic parts. Phthalates and PAHs come from plasticisers and oils in these materials, often supplied by small traders.
Water-repellent finishes. Fluorinated finishes on textiles can contain PFHxA-related substances, restricted for consumer clothing since 10 October 2026.
SVHC declarations. Your buyer will ask for a statement that no Candidate List substance is above 0.1%. That statement needs material knowledge, not just a signature.

What testing is needed, and what inspection can check

REACH compliance is proven by tests at an ISO/IEC 17025-accredited lab, on materials taken from production. Common tests include azo amines to EN ISO 14362 (named in REACH Appendix 10), chromium VI in leather, nickel release, PAH and phthalate content, formaldehyde emission in a chamber, and SVHC screening.

An inspector at the factory can check	Needs lab testing
Fabric, leather, foam and board in production match the materials in the lab report (supplier, colour, lot)	Azo amines, chromium VI, nickel release, PAHs, phthalates, PFHxA
Supplier declarations and test reports are on file and cover the current lot	Formaldehyde emission from furniture or panels
No anti-mould sachets of unknown content packed with the goods	SVHC content above or below 0.1%
Samples drawn at random from production and sealed for the lab

A visual check cannot detect any of these chemicals. Its value is in making sure the tested material is the material that ships.

How Clear To Load checks this in India

We do not run chemical tests. Through lab testing coordination, the inspector draws samples from production, seals them and sends them to an ISO/IEC 17025-accredited lab you choose or we suggest. We then check the lab report against the goods: same material, colour and lot. We take no commission from labs.

During a home textiles inspection or furniture inspection, the inspector also checks material traceability and supplier documents. The report arrives within 24 hours of the inspection and ends in Cleared to load, Hold or Not cleared. To add REACH sampling to an order, book an inspection.

Sources

Frequently asked questions

Does an Indian exporter have REACH obligations?

Not directly. REACH duties fall on companies in the EU, such as the importer. In practice the importer passes them up the supply chain, asking for SVHC declarations, test reports and material information from the Indian supplier.

Is the 0.1% SVHC limit a ban?

No. Above 0.1% w/w, the supplier must pass on information and notify SCIP, and in some cases ECHA under Article 7(2). Bans come from Annex XVII restrictions or authorisation, which set separate limits for specific substances and uses.

What does REACH entry 77 mean for furniture?

From 6 August 2026, furniture and wood-based articles may not be placed on the EU market if formaldehyde released under the Appendix 14 chamber test conditions exceeds 0.062 mg/m³. The limit applies to the article, not only to the panels inside it.

Which REACH tests matter for cotton home textiles?

Usually azo amines (entry 43), the CMR list in entry 72 including formaldehyde, nonylphenol ethoxylates (entry 46a), and, for water-repellent finishes, PFHxA (entry 79). The buyer's restricted substances list often adds more.

Can an inspection prove REACH compliance?

No. Chemicals cannot be seen. An inspection confirms that production materials match the tested materials and that documents are in place; the lab test provides the proof.

Know before it ships

Tell us the product, the factory's city and your ready date. We confirm the inspector, the notice time and the price before you book.

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EU REACH for articles made in India: SVHCs, SCIP and Annex XVII