Industries Electronics, Cosmetics & Beauty
REACH in 2026: the checklist electronics manufacturers actually need
REACH obliges you to know, and to declare, what is inside the components you buy. What auditors ask for first, and how to have it ready before the 45-day clock starts.
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A single screw can put you in breach. If it contains a Candidate List substance above 0.1% of the screw's own weight, the obligation is triggered, no matter how small the screw is next to the product it sits in.
That is the detail auditors find most often, and it explains why REACH work is harder than it looks. The European regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals has been in force since 2007, and what changed for mid-sized electronics manufacturers is not the text. It is that customers now ask for proof, and that the SCIP database made the answers public. If you assemble boards, import enclosures or resell equipment under your own brand, you are almost certainly a downstream user and often an importer, and both roles carry obligations.
What REACH asks of you, in practice
Three obligations account for most of the work.
Article 33, communication down the chain. If an article you supply contains a substance from the Candidate List above 0.1% by weight, you must pass that information to your business customer without being asked, and to a consumer within 45 days of a request. The threshold applies to each article, not to the whole assembly.
SCIP notification. Since January 2021 the same articles must be notified to the European Chemicals Agency's SCIP database. That data is public, which means your customers can check your declarations without ever contacting you.
Restrictions under Annex XVII. Some substances are simply not allowed above a given concentration in given uses. This is not a disclosure obligation, it is a market-access one.
Good to know: an "article" under REACH is defined by its shape and function, not by how you buy it. A cable assembly is not one article. It is a set of articles, and the threshold applies to each of them separately.
The five documents auditors ask for first
| Document | What it proves | Where it usually breaks |
|---|---|---|
| Bill of materials with part numbers | You know what you are selling | Free-text descriptions instead of stable part numbers |
| Supplier declarations per part | Substance content is documented | Declarations addressed to "our products", not to a part |
| Candidate List version reference | Your data matches a known state of the law | No version or date recorded |
| Article 33 response procedure | You can answer within 45 days | No named owner, no template |
| SCIP submission records | You notified what you had to notify | Submitted once, never updated |
Auditors rarely start with chemistry. They start with whether your data is attached to something stable. A supplier declaration saying "all our products comply with REACH" proves nothing, because it names no substance, no part and no version of the Candidate List.
A sequence that works
- Freeze your part numbers. Everything downstream attaches to them, so if the same component appears under three internal references, fix that before anything else.
- Rank parts by volume and by exposure. The parts you ship most of, and the parts going to customers with the strictest procurement rules, are worth the effort. The long tail can wait.
- Ask suppliers per part, with a deadline and a version. "Does part 4471-B contain any substance on the Candidate List as published on [date], above 0.1% w/w? If yes, name it and give the concentration." A specific question gets a specific answer.
- Record the answer, the date and the Candidate List version. Without the version you cannot tell later whether the answer is stale.
- Set a review trigger on Candidate List updates. Twice a year, check the new entries against your substance data rather than re-canvassing every supplier.
- Write the Article 33 response procedure down. One named owner, one template, one place the data lives.
Mistakes to avoid
Treating REACH as a purchasing questionnaire. Collecting signed statements is not the same as knowing what is in your parts. The statement is evidence; the substance data is the answer.
Applying 0.1% to the finished product. This under-declares, and it is the error most often found in audits.
Collecting once. The Candidate List grows, so a declaration from two years ago describes a shorter list than the one you are held to today.
Waiting for a customer to ask. Building the data set from scratch inside 45 days is not realistic for a catalog of any size.
Where to keep the data
Somewhere queryable by part number, with a date and a source document per answer. A compliance platform does this and keeps the review triggers; a well-structured shared drive with a strict naming convention also works, provided someone owns it.
So build the answer before the question arrives, and test it with the query that matters: which of our parts contain this newly listed substance? If your data cannot answer that in an afternoon, the 45-day clock is going to be a problem, and it starts without warning.
FAQ
Does REACH apply if we only import finished components and assemble them?
Yes. Importing an article into the EU makes you responsible for Candidate List communication under Article 33 and for SCIP notification, even if you carry out no chemical process yourself. Assembly does not transfer the obligation to your supplier.
How is the 0.1% threshold calculated?
It is calculated per article, based on the weight of that article, not on the weight of the finished assembly. A screw containing a Candidate List substance above 0.1% of the screw's weight triggers the obligation, regardless of how small the screw is relative to the product.
How long do we have to answer a request about a substance of very high concern?
For a consumer request, 45 days from the date of the request, free of charge. For business customers, the information must be provided when the article is supplied, without waiting for a request.
How often is the Candidate List updated?
Typically twice a year. Each update can add substances that were not covered by declarations you collected earlier, which is why declarations should record the Candidate List version they refer to.
