The Candidate List moves twice a year. Your watch process should too.

On February 4, 2026, ECHA (the European Chemicals Agency) added n-hexane and bisphenol AF to the Candidate List of substances of very high concern under REACH, the EU regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals. The list now carries 253 entries, up from 240 in January 2024. For a manufacturer or importer of equipment, each addition can pull one of your components into the scope of Article 33 overnight. The update itself is free and public. What costs money is finding out about it from a customer.

Two windows a year, January and June, with no guarantee attached

The recent record shows the rhythm, and its exceptions.

Two lessons sit in that table. First, the semiannual rhythm is real: since 2024, every year has had a winter update and an early-summer update. Second, ECHA does not owe you the calendar. November 2024 brought an off-cycle addition, triphenyl phosphate, a flame retardant and plasticizer used widely in electronics, and November 2025 brought another one, decabromodiphenyl ethane. The winter 2026 update slipped to February. A watch process built on "check in January and June" misses all three cases; one built on the publication event catches everything.

Additions are not the whole story either. ECHA also revises existing entries: the January 2024 update amended the dibutyl phthalate entry to add its endocrine-disrupting properties for the environment, and the January 2025 update revised the entry for TNPP (tris(4-nonylphenyl) phosphite), already listed since 2019, to state that its endocrine-disrupting properties hold whether or not it contains 4-nonylphenol. A watch that only counts new lines misses a substance you already declared changing its legal profile.

An update is a differential, not a new project

The February 2026 update added two substances. Your screening job that week was two CAS numbers, not 253. At an equipment manufacturer I work with, that screen took an afternoon in February and three weeks the year before, on the same catalog. Nothing about the list changed in between: the difference was that the substance data had been attached to part numbers. That is the entire economic argument for keeping substance data attached to part numbers: a portfolio you can query by CAS number turns each update into an afternoon of work, and a folder of supplier certificates saying "REACH compliant" turns it into a re-canvassing campaign.

The screen itself is short. Take the new entries, with their CAS and EC numbers. Query your substance declarations for them, part by part. Three outcomes: the substance is absent from your data and you record that finding with the date; it is present below 0.1% weight by weight of the article and you record that too; or it is present above 0.1%, and the obligations below start applying to that part.

Good to know: ECHA publishes a Registry of Intentions listing the substances proposed for identification months before a vote. Screening your portfolio against the intentions, not just the inclusions, converts a legal deadline into an early warning, and costs one extra query.

Listing a substance starts several clocks, and you only control one of them

The day a substance you use joins the list, three obligations wake up at different speeds.

Immediately: Article 33(1). From the moment of inclusion, every business customer you supply the article to must receive enough information for safe use, at minimum the name of the substance, with the delivery and without being asked. There is no grace period written into the text.

Within six months: notification to ECHA. Under Article 7(2), producers and importers must notify ECHA when a Candidate List substance is present in their articles above 0.1% weight by weight and above one metric ton per year in total, no later than six months after inclusion. Since January 5, 2021, the same articles also belong in the SCIP database, the EU's public register of substances of concern in articles, which your customers can consult without ever contacting you.

Whenever a consumer decides: Article 33(2). A consumer may ask whether an article contains a Candidate List substance above 0.1%, and you owe them an answer within 45 days, free of charge. That clock starts on the date of their request. If your data cannot answer the question in an afternoon, the 45 days are a deadline for building a dataset, which is not what they were designed to be.

A watch process that works has four dated steps

1. Subscribe to the event, not the season. Follow ECHA's Candidate List page and its update announcements directly, so an off-cycle addition reaches you the week it happens.
2. Screen the new entries against your parts. By CAS number, against per-part substance data. Record the result of the screen even when it is "not present": a dated negative is evidence, an undocumented one is a gap.
3. Update what the screen touches. Refresh the Article 33 information going to affected customers, file or update the SCIP dossiers concerned, and put the ECHA notification in motion where the one-ton threshold is met. Re-question suppliers only for the parts the update actually touches.
4. Stamp everything with the list version. A declaration referring to "the Candidate List" is undated evidence. One referring to "the Candidate List of February 4, 2026, 253 entries" tells you exactly when it expires: at the next update.

The next usual window is June or July. Before it opens, run the February update through your process as a drill: how long does it take you to say which of your part numbers contain n-hexane or bisphenol AF? If the answer comes in days, your watch works. If it comes in weeks, fix the process now, while no 45-day clock is running.

FAQ

How often is the REACH Candidate List updated?

Roughly twice a year, historically in January and June or July, but the calendar is not guaranteed: ECHA added a substance off-cycle in November 2024 and again in November 2025, and the winter 2026 update landed on February 4. As of that date the list holds 253 entries.

What do we have to do when a substance we use is added to the Candidate List?

Three things on three clocks. Immediately, give business customers the information required by Article 33(1), at minimum the substance name, with each supply of the affected article. Within six months, notify ECHA if the substance exceeds 0.1% by weight in your articles and one metric ton per year in total, and update the SCIP database. And be ready to answer a consumer request within 45 days at any time.

Does the 45-day deadline start when the Candidate List is updated?

No. The 45 days of Article 33(2) run from the date a consumer asks whether an article contains a Candidate List substance above 0.1% by weight. The request can arrive on any date, and the answer is owed free of charge. Information to business customers is due with the supply itself, without any request.