The European Chemicals Agency (ECHA) has recently updated and added three new substances to the Candidate List of Substances of Very High Concern (SVHCs). As regulatory news doesn’t only impact regulatory compliance, it signals to industries to undertake review, assessment and possibly redesign and change their chemical use. For manufacturers, importers and users, understanding what it means to the chemical industry and their operation is paramount for compliance, product safety and sustainability.
What Does the Candidate List Set Out to Achieve?
The Candidate List forms a part of the REACH Regulation (Registration, Evaluation, Authorisation and Restriction of Chemicals). The Candidate List includes substances that are thought to be capable of causing serious effects on human health or the environment. When a substance is placed on the Candidate List, it is also classed as an SVHC, and may be subject to authorisation and/or restriction requirements in the future.
If a substance is put on the Candidate List, companies that manufacture, import or use these substances (when alone, in mixtures, or in articles) will have obligations under REACH indicating that safe use instructions must be provided for their compilation, sharing of information to their supply chain partners, and possibly preparatory actions for substitution.
What Are the New Additions?
On June 25, 2025, ECHA has included three chemicals in the Candidate List:
- 1,1,3,5,5,5-heptamethyl-3-[(trimethylsilyl)oxy]trisiloxane
Used in cosmetics and personal care products and perfumes and fragrances
- Decamethyltetrasiloxane
Used in cosmetics and personal care products, used in lubricants and greases and is used in automotive care products
3.Reactive Brown 51
Used in textile treatment products and dyes and were marked Toxic for reproduction
With these new substances , the Candidate List will now contain 250 substances. Each modification increases scrutiny of chemical compositions across all industries.
Why should businesses take notice?
There are implications to being listed as an SVHC that extend beyond compliance. Here are some of the reasons why the Candidate List matters the most:
- Supply Chain Impacts
If your suppliers are using SVHCs, you may need to find alternatives or redesign your components.
- Regulatory Burden
There are obligations associated with the use of SVHCs, for example, the need to update safety data sheets, notify ECHA under Article 7 of REACH, and to notify consumers if requested.
- Market Access Risk
There may be restrictions in the future for products with these substances in EU markets, or may require authorization, which both takes time and is costly. - Brand & Sustainability Implications
Consumers and clients are increasingly concerned about environmental and health safety perspectives. Being proactive about compliance with chemicals with SVHCs will improve your reputation.
What to do About Candidate List Updates
For companies located in or exporting to the EU, here’s what to do when new SVHCs are added to the Candidate List:
- Assess Your Inventory: Examine your raw materials, formulations, and components for the substances newly added.
- Contact Your Suppliers: Communicate with your suppliers, and verify the presence of SVHCs in your supplied products.
- Update Your Compliance Information: If you manufacture articles that contain any SVHC over 0.1% weight by weight, make notifications to your customers/information to your customers in ECHA.
- Evaluate Alternatives: Start to consider safer options or re-formulating your products especially if it is most likely that your products will be subject to authorisation.
- Plan Ahead: Even if you are not directly impacted by this update, new Candidate List substances are common. Planning ahead of these updates will position you far ahead of your competitors.
The Importance of Technical Partners Related to Compliance
Dealing with regulatory change such as ECHA’s updates can be tough, especially when you are working on the product, manufacturing deadlines and on top of it, supply-chain issues. This is where partnerships come in.
At SunStream , We help businesses deal with regulatory complexity by providing SDS Services and REACH compliance services , proper documentation, product compliance consulting and risk assessment for materials and chemicals . Our services provide manufacturers the ability to comply with regulation while being efficient and competitive.
Whether you need to audit your existing chemical use, advance your documentation for REACH, or require some engineering support to replace SVHCs, we will give you the clarity and support for execution.
The ECHA Candidate List is not just for chemical companies. Every business that uses, sells, or ships products across Europe will be impacted. With three more substances being added, this is a reminder for all manufacturers to reassess both their material inputs and their compliance processes.
Staying current and proactive so that you are not caught off guard when regulatory actions updates or when customers demand better transparency and eco-friendliness. Now is a good time to align your compliance with smarter and cleaner product strategies.
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