Answering an Article 33 request without a full material declaration program

At an electronics board manufacturer I work with, the request landed on a Friday: a forty-tab spreadsheet, full chemical composition demanded part number by part number, fifteen days to comply. The company had no material declaration program, no dedicated software, and nobody whose job this was. It answered on time, because what the law requires is far narrower than what the spreadsheet asked for.

The obligation is narrow: one list, one threshold, one piece of information

The European REACH regulation (Registration, Evaluation, Authorisation and Restriction of Chemicals, Regulation (EC) No 1907/2006) devotes one article, Article 33, to information on substances in articles. Its perimeter fits in three boundaries. The list: only substances of very high concern (SVHC) on the Candidate List count, 253 entries as of the update of February 4, 2026, and the list grows roughly twice a year. The threshold: 0.1% by weight, calculated per article rather than on the finished product, since the Court of Justice of the European Union ruled so on September 10, 2015 (case C-106/14). The information: the "sufficient information, available to the supplier" to allow safe use, including "as a minimum the name of that substance".

Who asks changes the clock, not the content. A business customer must receive the information at delivery, without asking. A consumer must receive it on request, free of charge, within 45 days.

And if no Candidate List substance exceeds the threshold in any article of the product, Article 33 asks nothing of you. No certificate, no lab report, no full composition, no signed attestation. The forty-tab spreadsheet is a commercial requirement from the buyer, not a regulatory one, and nothing stops you from answering the legal question precisely while negotiating the rest.

Good to know: since January 2021, the same articles must also be notified to the SCIP database of the European Chemicals Agency, and that data is public. An Article 33 answer that contradicts your own SCIP notifications will be noticed.

Your suppliers already owe you the answer

You do not have to discover what your components contain. Your suppliers owe you that information under the same Article 33, automatically and at no cost, every time they deliver. So your customer's question travels upstream, with three additions that separate a reminder email from an actual answer.

1. Per part number. "Does part 2203-A contain any Candidate List substance above 0.1% of the part's own weight? If yes, which one and at what concentration?" A question about a part gets an answer about a part. A question about "your products" gets a slogan.
2. With the list version. Name the Candidate List publication date you are asking against. An answer with no date describes a shorter list than the one you will be held to.
3. With your customer's deadline. The 45 days are yours only if the requester is a consumer. Pass the real date on, minus your own margin.

And keep the perimeter tight. The request concerns one delivered product, not your catalog. Querying only the suppliers of that product's parts is the difference between ten emails and three hundred.

IEC 62474 and IPC-1752A are the formats your industry already speaks

A PDF attestation stating "REACH compliant" names no substance, no part, and no list version: it does not answer the question, and it will not serve the next one. Electronics has two formats built for this.

IEC 62474, the material declaration standard of the International Electrotechnical Commission for the electrotechnical industry, maintains a declarable substance list online: around 200 substances and substance groups, covering among others the REACH Candidate List and RoHS (the EU directive restricting hazardous substances in electronics), each with its reporting threshold, plus an XML exchange schema.

IPC-1752A, the materials declaration management standard published by IPC, exchanges the same data as XML files, with two useful levels: Class C, a declaration against a substance list, and Class D, full material disclosure down to homogeneous materials.

Requesting these formats instead of an attestation changes what you collect: one dated, machine-readable record per part, which the large component distributors already produce on demand. The next request becomes a search through your own files.

Answer the request that was made: the parts of the delivered product, a dated Candidate List, the threshold per article, the information you hold. File each supplier answer by part number with its date and list version, and require the XML wherever the supplier can produce it. The material declaration program will have started without anyone deciding to launch it, one request at a time.

FAQ

Do we have to answer if no Candidate List substance exceeds 0.1% in the product?

Article 33 imposes no obligation in that case. In practice, answer anyway with an explicit statement naming the Candidate List version and date you checked against, because in practice buyers escalate when they get no answer at all.

Is the 0.1% threshold calculated on the finished product?

No. Since the Court of Justice of the European Union's ruling of September 10, 2015 in case C-106/14, the threshold applies to each article incorporated in a complex product, based on that article's own weight.

Does Article 33 require a test report or a compliance certificate?

No. The regulation requires sufficient information available to the supplier to allow safe use of the article, including as a minimum the name of the substance. Test reports, certificates, and full composition breakdowns are commercial requests, not legal obligations under Article 33.

What is an IEC 62474 or IPC-1752A declaration?

Both are XML-based material declaration formats used in the electronics industry. IEC 62474 provides a maintained list of declarable substances with reporting thresholds and an exchange schema. IPC-1752A defines declaration classes, from a declaration against a substance list (Class C) to full material disclosure (Class D). Both are machine-readable and reusable across customer requests.