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EU REACH · ARTICLE 7
Article 7 – Substances in Articles
Registration and notification duties for substances contained in, or intended to be released from, articles.
When an article itself carries a registration or notification duty.
Article 7 addresses substances that sit within articles rather than being placed on the market as a substance or mixture in their own right. Where a substance is intended to be released from an article under normal or reasonably foreseeable conditions of use, and the total quantity present across a producer or importer’s articles exceeds one tonne per year, that substance must be registered in the same way as any other substance placed on the market.
A related notification duty applies where an article contains a substance of very high concern (SVHC) from the Candidate List above 0.1% weight by weight, and the total quantity across those articles exceeds one tonne per year, unless exposure to people or the environment can be excluded throughout the article’s life cycle.
In practice, this means article manufacturers and importers cannot assume that supplying a finished product removes them from REACH’s scope. Where a coating, additive, or component is designed to be released in use, or where an SVHC is present above the threshold, the same registration and notification questions arise as for a substance sold on its own.
For more on how the Candidate List and Authorisation List work, and what they mean for your organisation, see our guide to Substances of Very High Concern (SVHCs), or our guide to REACH Authorisation for what happens once a substance reaches the Authorisation List.
✓Screening product ranges to identify substances intended to be released in normal use
✓Quantifying substance tonnage across an article range to test against the one tonne threshold
✓Candidate List (SVHC) screening of articles at the 0.1% weight-by-weight threshold
✓Supporting registration or notification decisions and the underlying evidence
✓Creating and maintaining a central substance repository alongside your bill of materials, so the underlying data does not live in scattered spreadsheets
✓Helping you understand the trigger points for Article 7 and where your organisation’s role and duties sit in the wider REACH supply chain
When does the Article 7 notification duty trigger?
Article 7 covers two related but distinct duties. The path below shows the questions that decide whether either applies to a given article.
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Identify the article
Does the article contain one or more substances, rather than being a simple, unworked material?
Check release intent
Is a substance intended to be released from the article under normal or reasonably foreseeable use?
Calculate tonnage
Does the total quantity of that substance across the producer or importer’s articles exceed 1 tonne per year?
Check for SVHCs
Separately, is a Candidate List substance present above 0.1% weight by weight, at over 1 tonne per year in total?
Registration or notification
If either threshold is met, and exposure cannot be excluded, registration or notification to ECHA is required.
How we help with Article 7
Meeting the Article 7 duty well means being able to find the substances that trigger it, prove the working behind that conclusion, and submit and manage the notification itself.
Identifying substances that trigger notification
We screen product ranges and bills of materials to find substances intended to be released in use, and screen separately against the Candidate List for SVHCs above the 0.1% threshold.
Recording and evidencing the assessment
We build and maintain structured records of tonnage calculations, release assessments and threshold checks, so the reasoning behind a notify or don’t notify decision is there when it is asked for.
Drafting and provisioning the notification
We prepare the technical content of the ECHA notification or registration submission itself, ready for provision through the appropriate route.
Managing supply chain and regulator communications
We coordinate with suppliers to obtain the composition data a notification depends on, and act as the point of contact for any ECHA or regulator queries that follow.
Ready to talk through your requirement?
Tell us where the uncertainty sits. We will help you define the requirement and the right level of support.
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