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EU REACH · ARTICLE 33

Article 33 – Communicating Substances in Articles

The duty to tell customers and consumers when an article contains a substance of very high concern.

Keeping the supply chain informed about SVHCs in articles.

Article 33 requires suppliers of an article containing a Candidate List substance of very high concern (SVHC) above 0.1% weight by weight to provide the recipient with enough information, as a minimum the substance name, to allow safe use of the article. This duty applies down the supply chain to professional and commercial customers automatically.
Consumers have a parallel right to ask a supplier whether an article they have bought contains an SVHC above the threshold, and suppliers must respond free of charge within 45 days of the request.
Because the Candidate List grows over time, an article that did not trigger Article 33 when it was first placed on the market can become subject to it later, simply because a substance it contains has since been added to the list. Article 33 compliance is therefore an ongoing monitoring exercise, not a one-off check.

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.

✓Bill-of-materials screening against the current Candidate List
✓0.1% weight-by-weight threshold calculations across complex or multi-part articles
✓Drafting supply chain and consumer-facing Article 33 communications
✓Setting up a monitoring process so new Candidate List entries are checked against existing products
✓Creating and maintaining a central substance repository alongside your bill of materials, so SVHC data does not live in scattered spreadsheets
✓Helping you understand the trigger points for Article 33 and where your organisation’s role and duties sit in the wider REACH supply chain

When does the Article 33 communication duty trigger?

Article 33 creates both an automatic supply chain duty and a consumer duty that only applies on request. The path below shows how the two differ.

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Screen against the Candidate List
Does the article contain a substance currently on ECHA’s Candidate List of substances of very high concern?
Check the concentration
Is that substance present above 0.1% weight by weight in the article, or a defined part of it?
Supply chain duty applies
If so, safety information must be provided automatically to professional and commercial recipients down the supply chain.
Consumer request received
Separately, if a consumer asks whether the article contains the substance, a response is required.
Respond within 45 days
The supplier must confirm the substance and provide safe-use information, free of charge, within 45 days of the request.

How we help with Article 33

Article 33 is an ongoing monitoring duty as much as a one-off check, since a product can become in-scope later if a substance it contains is added to the Candidate List.

Identifying substances that trigger notification
We screen bills of materials against the current Candidate List and calculate concentrations across complex or multi-part articles to establish where the 0.1% threshold is met.
Recording and evidencing the assessment
We maintain SVHC screening records and concentration calculations, and set up a monitoring process so new Candidate List entries are checked against existing products automatically.
Drafting and provisioning the notification
We draft the safety information communicated down the supply chain, and the consumer-facing response used when a request is received.
Managing supply chain and regulator communications
We handle consumer enquiries within the 45-day window, and coordinate with suppliers further up the chain to obtain the substance data these communications depend on.
EU REACH · ARTICLE
Article 66
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