Many companies not informed about SVHCs in their articles

30 / 11 / 2018

The LIFE AskREACH project aims to improve the way companies handle SVHCs in their supply chains and respond to consumer information requests in terms of REACH Art. 33 using the project tools. In order to review the current situation of companies, online surveys were conducted in 12 partner countries.

Of 174 participating companies, 43% had already received ‘right to know’ information requests from consumers. French companies reported receiving an average of 84 requests a month.

Of the companies that have received requests, nearly half did not usually have the information required to provide an immediate response. In addition, only 47% of the participating companies felt well informed or quite well informed about the presence of SVHCs in their articles. This may be linked with the finding that 43% of the surveyed companies had no IT-solution in place to collect and manage information on SVHCs in their articles. Of the companies that do employ IT tools (57%), a quarter use MS Excel.

The survey findings confirm concerns that a large proportion of companies are not well-prepared to respond to consumer’s ‘right to know’ requests in compliance with REACH Art. 33.

A major reason for companies’ difficulties may be the lack of supply chain communications on SVHCs in articles. These challenges could be tackled with a supply chain communications approach heading towards full material declaration (FMD). Steps in this direction are supported by the supply chain tool developed by the LIFE AskREACH project together with pilot companies.
Also, more than half of the participating companies (57%) agreed that it is technically complicated to comply with Article 33(2).

The LIFE AskREACH project is developing a Europe-wide smartphone app for consumers to launch information requests in accordance with REACH Art. 33. The app will be connected to a database with information on SVHCs in articles, thereby simplifying and speeding up the responses by the article suppliers. Half of the companies participating in the survey believe that such an approach could be helpful.

The link to access the survey was widely distributed via newsletters (including the ECHA Newsletter) to attract a large number of participants. Between June and September 2018, 174 companies returned the questionnaire, most of them from France (67), Germany (50), Sweden (15), and the Czech Republic (12).
59% of the enterprises described themselves as small or medium-sized enterprises (< 250 employees). Sectors most frequently represented include “textiles, clothes, shoes and accessories (other than outdoor)”, electronics (computers, televisions, washing machines, blenders, smartphones, etc.), and domestic articles (other than electronics; kitchen utensils, decorative products, etc.).

The participating companies are not representative of the actual distribution of companies in these countries, so that it is not possible to draw generalised conclusions. Nevertheless, the survey results do show trends about REACH Art. 33 implementation.

Companies that are interested in taking part in the beta testing of the database supplier frontend should send an e-mail to Companies interested in the supply chain tool can contact


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