The UK SVHC Candidate List is the list of substances identified as Substances of Very High Concern under UK REACH. When a substance is included, the suppliers of that substance take on obligations, chiefly the duty to communicate its presence in the mixtures or articles they supply.
A listing also carries a forward-looking signal, since inclusion on the Candidate List can be an early warning that a substance may face stricter controls in the future, including possible authorization requirements. Companies that follow the list closely therefore learn about a substance's regulatory direction at the same moment they learn about their present duties.
The UK REACH Candidate List names Substances of Very High Concern. A listing obliges suppliers to communicate the substance's presence in their mixtures or articles and can signal future authorization requirements.
The obligations start immediately, because there is no transition period when a substance is added to the Candidate List and the date of inclusion is the effective date. Publication follows no predetermined schedule either, so a company cannot plan around a fixed calendar and has to monitor the list continuously to learn that a new substance has been included. On June 15, 2026, for example, HSE added 15 substances or substance groups to the UK Candidate List, and the duties for each applied from that day.
With no transition period, supplier outreach, documentation updates, and customer communication all happen after publication, so the preparation has to exist before any substance is named.
UK Candidate List obligations start on the date of inclusion. There is no transition period, and publication follows no fixed schedule, so the list has to be monitored continuously.
Anyone placing substances, mixtures, or articles on the market in Great Britain (England, Scotland and Wales) is responsible for complying with the communication duties that follow a Candidate List update. The obligation therefore reaches chemical suppliers and manufacturers of finished goods alike, and the specific duty depends on whether the company supplies a substance, a mixture, or an article.
UK REACH places the responsibility on businesses to understand the chemicals they place on the market and to communicate appropriate information through the supply chain.
Anyone placing substances, mixtures, or articles on the market in Great Britain is responsible under UK REACH, from chemical suppliers to manufacturers of finished goods.
Candidate List inclusion leaves a product free to be sold and adds communication and notification duties for its supplier. The listing does not constitute a restriction or a ban, and it signals that the substance could later be considered for authorization. Nicholas Galbussera of Trace One describes the measure this way:
"Candidate List inclusion is not primarily a restriction measure; it is an information-management measure."
- Nicholas Galbussera, Trace One
The point matters in practice because a customer who hears that a substance has been listed may worry that a product has to come off the market. The more accurate concern is the immediate compliance work that a listing sets off, which has to be done correctly and on time, and which centers on establishing where the substance sits in the company's portfolio and what the company must now say to others about it.
No. Candidate List inclusion is not a restriction or a ban. It creates communication and notification duties for the supplier and signals that the substance could later be considered for authorization.
When an article contains a Candidate List SVHC above 0.1% weight by weight (w/w), the supplier must communicate information down the supply chain and respond to consumer requests. Consumers are entitled to receive that information within 45 days of asking.
A supplier that already holds current composition data can answer from its records. One that starts investigating after the request arrives is already on the clock.
Above 0.1% w/w in an article, suppliers must communicate SVHC information down the supply chain and give consumers the information within 45 days of a request.
For most companies, the biggest change is new supply-chain and documentation work. Each time a substance is added to the Candidate List, a team needs to check whether that substance is present in its substances, mixtures, or articles, obtain updated information from suppliers, update safety data sheets (SDSs) and other compliance records where required, and communicate the relevant SVHC information to customers.
A customer may also need to trace the presence of the substance through its own supply chain and provide updated data to its own customers, so the work extends beyond a single team and beyond a single company. Each step depends on the previous one, since a team cannot update an SDS or notify a customer until it knows whether the substance is present, and it cannot know that without information from suppliers.
Regulatory Affairs is the team most likely to be affected first, since it is responsible for noticing the update, determining whether the substance is present, and starting the supplier and customer communication that follows.
Each Candidate List update triggers the same chain: check presence, obtain supplier data, update SDSs and records, then inform customers. Regulatory Affairs is usually the first team affected.
The hardest part is rarely identifying the newly listed substance and much more often proving whether it is present in a complex supply chain. When the UK Candidate List changes, companies may discover that they need updated supplier declarations, bill of materials (BOM) reviews, or material composition data before they can determine whether any communication or notification obligation has been triggered.
Reliable composition information is difficult to obtain from suppliers, particularly for complex articles and multi-tier supply chains, where the party that knows what a component contains may sit several steps away from the company that must answer for it. A listing can therefore expose gaps in data that were invisible until the moment someone needed to rely on it, and closing those gaps takes time that a regulation with no transition period does not allow.
The regulation itself is straightforward and leaves little room for interpretation, so the difference between companies is operational readiness: how quickly a listing is noticed, how current the supplier data is, and how fast the information reaches customers.
The hardest part of UK SVHC compliance is proving whether a newly listed substance is present in a complex, multi-tier supply chain, not identifying the substance itself.
The UK and EU Candidate Lists are no longer aligned, so a company selling in both markets cannot assume that a substance listed in one jurisdiction is listed in the other. Regulatory teams need to monitor the two lists separately and keep their supplier data and customer communications consistent with each.
Yes. The UK and EU Candidate Lists are no longer aligned, so companies selling in both markets need to monitor each list and manage supplier data and communications for each.
The main risk is regulatory non-compliance, which can lead to enforcement action such as fines and, if the non-compliance remains unresolved, to potential restrictions on placing products on the GB market. The most common route into that position is a missed update, where a company fails to realize a new substance has been published and therefore does not tell its customers that the substance is present in its product.
UK SVHC non-compliance can lead to fines and, if unresolved, restrictions on placing products on the GB market. The most common cause is a missed Candidate List update.
Trace One supports customers by monitoring the regulatory source and providing updated data as soon as it becomes available, so Regulatory Affairs teams can begin checking their products, suppliers, and documentation right away. With no transition period in the legislation, speed of awareness is the practical advantage, since the earlier a team knows that a substance has been listed, the more time it has to confirm presence, obtain supplier declarations, update SDSs, and notify customers.
The main risk Trace One helps customers avoid is the missed update, where a company never realizes that a publication has happened and therefore never informs its customers that a newly listed substance is present in its product.
After the transition periods, cosmetic products without the new fragrance allergen labeling cannot continue to be placed on the EU market, which means relabeling, delayed launches, and withdrawals.
Maintain current supplier declarations, BOM data, and material composition information for the substances, mixtures, and articles you supply, so that a listing can be checked against records that already exist.
Check each new listing against your portfolio to establish whether the substance is present, including in components sourced through multi-tier supply chains.
Compare the concentration in articles against the 0.1% w/w threshold to determine whether supply chain communication and consumer response duties apply.
Update SDSs and other compliance records where required and communicate the information to customers and downstream users.
Keep a process in place to answer consumer requests within 45 days and track the UK and EU lists separately.
See how Trace One SDS helps chemical suppliers keep safety data sheets and customer communication current.
Trace One is a global provider of AI-native Product Lifecycle Management (PLM) and regulatory compliance software for the food & beverage, cosmetics & personal care, and specialty chemical industries. With more than 30 years of industry expertise, the company helps over 9,000 brands worldwide develop, launch, and manage remarkable products faster. Purpose-built for formula-based product development, its platform connects the entire product lifecycle from ideation to launch, with integrated regulatory intelligence spanning 170+ countries. Learn more at traceone.com.