Short answerSubstance compliance means knowing which regulated chemicals sit in which component of every article. REACH SVHC above 0.1% weight by weight triggers communication duties and SCIP notifications, RoHS caps ten substances in electrical equipment, and PFAS restrictions keep widening. The reliable model links supplier material declarations to components in the PLM bill of materials.
Key takeaways
- REACH Article 33 obliges suppliers to communicate any Candidate List SVHC present in an article above 0.1% weight by weight, and the Candidate List is updated roughly twice a year.
- Since 5 January 2021, suppliers of such articles on the EU market must also notify them to the ECHA SCIP database under the Waste Framework Directive.
- Full material declarations to IPC-1752A let a company re-screen its whole portfolio against new restrictions without going back to every supplier.
Substance compliance is a bill of materials problem
Substance regulations apply thresholds at the level of the article or homogeneous material, so compliance depends on component-level data. A finished product is compliant only if every part, coating, adhesive and cable meets each restriction that applies to it. That makes the engineering or manufacturing BOM in PLM the natural backbone, as described in BOM management. Spreadsheets of supplier certificates detached from the BOM cannot answer the questions authorities and customers ask.
Four regimes drive most of the data demand
Each regime uses a different threshold logic, which shapes the attributes required.
| Regime | What it controls | Threshold logic | Key data |
|---|---|---|---|
| REACH SVHC (Article 33) | Candidate List substances in articles | 0.1% w/w per article, including each component article | CAS number, concentration, location |
| SCIP database | Notification of articles containing SVHC | Same 0.1% w/w trigger | Article identity, SVHC, safe use information, TARIC code |
| RoHS Directive 2011/65/EU | Ten substances in electrical and electronic equipment | 0.1% w/w per homogeneous material (0.01% for cadmium) | Homogeneous material data, exemptions |
| REACH Annex XVII and PFAS rules | Restricted substances and uses | Varies by entry | Restriction entry, concentration, use |
The Candidate List held 253 entries in October 2026, unchanged since the February 2026 update, and grows with each update, roughly every six months. PFAS add further pressure: an EU restriction on undecafluorohexanoic acid (PFHxA) applies in stages, national PFAS bans are spreading, and the universal PFAS restriction proposal submitted in 2023 is still under assessment: ECHA's risk committee adopted its opinion in March 2026, the socio-economic committee's final opinion is expected around the end of 2026, and a Commission decision follows after that. Packaging rules add their own PFAS limits for food contact packaging, which connects this topic to PPWR explained.
Choose full material declarations over yes or no certificates
Declaration quality determines how quickly a company reacts to new restrictions. Three types are common.
- Declaration of conformity: the supplier confirms compliance with a named regulation at a point in time. It expires when the list changes.
- Query or exception declaration: the supplier reports only listed substances above thresholds, often using IPC-1752A Class C or IEC 62474 reportable substances.
- Full material declaration (FMD): the supplier discloses every material and substance with CAS numbers and mass, for example IPC-1752A Class D.
An FMD lets compliance teams re-screen the entire portfolio automatically when ECHA adds a substance, without a new supplier campaign. Suppliers protect formulations, so FMDs typically allow confidential substances to be declared as aggregated or masked entries. Electronics and automotive supply chains are most mature here; automotive relies heavily on IMDS. Consumer goods and furniture suppliers often provide only conformity statements, which drives repeated data requests.
Link declarations to parts in PLM and roll up results
The data model connects four levels: substance, material, part and product.
- Substance master: CAS and EC numbers, regulatory list memberships and threshold rules, refreshed from ECHA and other sources.
- Supplier part: the manufacturer part number linked to its declaration, declaration type, date and validity.
- Internal part: the PLM item mapped to one or more approved supplier parts, with mass and homogeneous materials.
- Product roll-up: automated calculation of SVHC presence per article, RoHS status, exemption use and SCIP notification need.
Dedicated compliance tools often run the calculations, while PLM keeps the part and BOM structure. The compliance status then flows to ERP for shipment blocks and to PIM for customer-facing information, such as REACH Article 33 statements and SCIP numbers. Data flows follow the patterns in integration patterns for PLM, ERP, PIM and DAM. Comparing how PLM platforms handle material compliance is easier with the PLM vendors overview.
Plan the supplier campaign as the main effort
Supplier data collection dominates cost and duration. A first full campaign typically takes an estimated 6 to 12 months and reaches 70 to 90% declaration coverage by part count, with the long tail of small suppliers hardest to close. Prioritise by risk: electrical components, plastics, coatings, textiles and imported parts first. Set contractual obligations for declaration updates, track declaration age, and treat missing data as non-compliant until proven otherwise. The same substance data later feeds digital product passports, where substances of concern are a core information requirement under the ESPR ecodesign regulation.
Frequently asked questions
What is the SCIP database?
SCIP is the ECHA database for information on Substances of Concern In articles as such or in complex objects (Products). Since 5 January 2021, suppliers placing articles containing Candidate List SVHC above 0.1% weight by weight on the EU market must submit a notification, giving waste operators and consumers access to the information.
What is the difference between REACH and RoHS?
REACH regulates chemicals across almost all products and requires communication of SVHC in articles above 0.1% weight by weight. RoHS applies only to electrical and electronic equipment and restricts ten specific substances per homogeneous material. Many electronics manufacturers must comply with both and need data at material level.
What is IPC-1752A?
IPC-1752A is an XML standard for exchanging material declarations between suppliers and manufacturers. Class C covers query or exception reporting against regulatory lists, while Class D is a full material declaration listing every substance with mass. Many compliance tools import IPC-1752A files directly and map them to parts.