EU chemical-information evidence · 31
Does a supplier REACH/SVHC declaration prove this charger meets EU requirements?
A declaration can support a named model, bill of materials and Candidate List reference date. It is not an ECHA approval and cannot cover an unidentified product or later material change.
Executive summary
A supplier REACH/SVHC declaration can map a named charger to a bill-of-materials revision, Candidate List reference date and constituent-article assessment, including the 0.1% w/w threshold used for Article 33 information duties. Overseas buyers should connect that dated basis to the exact model, components and responsible EU actor, because a generic “REACH compliant” letter is not ECHA approval and does not cover later substitutions, SCIP duties or every other REACH rule. ZIMONAI’s editorial view is that the declaration works best as the entry point to a traceable material-evidence chain, not as the final compliance verdict.
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Check the declaration’s product identity, legal issuer, bill-of-materials revision and Candidate List reference date before reading its conclusion.
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For a complex charger, the 0.1% w/w threshold applies to each constituent object that remains an article—not only to the finished charger’s total mass.
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Separate three questions: Article 33 communication, any SCIP duty for the EU market actor, and other REACH restrictions or authorisation issues. One supplier sentence does not resolve all three.
What does REACH Article 33 actually require?
ECHA states that an EU or EEA supplier of an article containing a Candidate List substance above 0.1% w/w must give professional recipients enough available information for safe use, including at least the substance name. A consumer can request similar information, which must be supplied free of charge within 45 days. These duties arise from the substance’s inclusion in the Candidate List; they are not created by a private test-report format or an ECHA product approval.
A Chinese exporter may provide the upstream data needed for this assessment, but the official ECHA summary assigns the market-facing duties to EU or EEA producers, importers and suppliers according to their role. A buyer should therefore ask who will place the charger on the EU market and who has reviewed the product information, rather than treating the exporter’s letter as the end of the compliance chain.
Why can a one-page “REACH compliant” statement be too broad?
The Court of Justice of the European Union held in Case C-106/14 that the 0.1% threshold applies to each article incorporated as a component of a complex product. ECHA’s guidance follows the same “once an article, always an article” approach. For a charger, the relevant evidence may therefore need to follow constituent articles such as a cable, enclosure part or connector; dividing one substance amount by the mass of the complete product can hide a component-level result above the threshold.
The Candidate List can change, and a charger bill of materials can change. A useful declaration should therefore state the exact model and variant, covered production or bill-of-materials revision, issuer and date, Candidate List cut-off date, substance identifiers or screening basis, threshold used and any exclusions. A genuine declaration for an older configuration does not automatically cover a new plastic, cable, solder, adhesive, connector or sub-supplier.
- Exact model, electrical variant and included cable or accessory
- Manufacturer or supplier legal name and authorised signatory
- Bill-of-materials or material-list revision and issue date
- Candidate List version or explicit reference date
- 0.1% w/w assessment at constituent-article level
- Named SVHCs and safe-use information when the threshold is exceeded
How should a buyer test the declaration before relying on it?
ZIMONAI’s practical method is to build a component-to-evidence matrix. Start with the quoted model and current bill of materials; identify higher-risk plastics, cable assemblies, connectors, coatings, solder and other constituent articles; then link each row to a supplier material declaration, test evidence or documented assessment. Record gaps instead of converting missing information into an assumed pass.
If an SVHC is reported above 0.1% w/w, obtain the substance name and sufficient safe-use information, then ask the responsible EU actor to confirm its Article 33 communication and whether a SCIP submission is required. If the supplier reports no Candidate List substance above the threshold, retain the dated basis and change-control link. This strengthens traceability, but it remains a sampled documentary assessment rather than proof of every unit or every REACH rule.
Buyer checklist
Buyer checklist
- Exact charger, power-adapter and accessory model identifiers
- Declaration issuer, legal entity, signature and issue date
- Current bill-of-materials or material-list revision
- Candidate List reference date and substance identifiers
- Constituent-article basis for the 0.1% w/w assessment
- Supporting material declarations, test reports or assessment records
- Documented controls for material and sub-supplier changes
- EU importer or supplier review of Article 33 and SCIP duties
Sources and evidence
Sources and evidence
Facts in this note were checked against the following primary and independent sources. Links open the source publisher’s website.
- 01European Chemicals AgencyCandidate List substances in articles — duties for producers, importers and suppliers
- 02European Chemicals AgencyCommunication in the supply chain — REACH Article 33 information duties
- 03European Chemicals AgencyGuidance on requirements for substances in articles, Version 4.0
- 04Court of Justice of the European UnionJudgment in Case C-106/14 — the 0.1% threshold applies to articles in a complex product
- 05European Chemicals AgencySummary of obligations resulting from inclusion of SVHCs in the Candidate List