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Topic
Article 33 of REACH is the obligation to communicate the presence of Substances of Very High Concern (SVHCs) in articles above 0.1% by weight. It applies to every supplier of articles in the EU and UK and is one of the most commonly under-implemented duties in chemical compliance.
Quick answer
Article 33 of REACH is the obligation on any supplier of an article containing an SVHC above 0.1% by weight to communicate that fact, plus enough information for safe use, to recipients. Article 33(1) covers B2B customers automatically; Article 33(2) covers consumers on request, free of charge, within 45 days. The 2015 CJEU ruling (Case C-106/14) confirmed the 0.1% threshold applies per article in a complex object, not to the finished product as a whole.
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See AI ERP for chemicalsArticle 33(1): any supplier of an article containing an SVHC above 0.1% w/w must provide the recipient (B2B customer) with sufficient information to allow safe use, including the name of the substance.
Article 33(2): the same information must be provided to a consumer on request, free of charge, within 45 days.
The Court of Justice of the European Union ruled in 2015 (Case C-106/14) that the 0.1% threshold applies to each article in a complex object, not to the finished product as a whole. A bicycle is not one article; the handlebar grip, the frame, the chain are each articles. This materially expands the number of products in scope.
At minimum: the name of the SVHC. In practice, recipients expect more, and a credible Article 33 communication usually includes:
Worldover for this
Worldover keeps the SVHC content of every article tied to suppliers and customers, and produces Article 33 statements and SCIP submissions on demand, in the right language.
See Article 33 in WorldoverSince 2021, suppliers placing articles containing SVHCs above 0.1% on the EU market must also notify the ECHA SCIP database. This is separate from but related to Article 33 and uses the same dataset.
Article 33 turns every SVHC update into a rolling customer-communication exercise. Each consumer request starts a 45-day clock, and every B2B shipment of an article above 0.1% w/w needs accurate, current information attached. Tracking that in spreadsheets and inbox threads is where compliance teams lose visibility and miss deadlines.
REACH compliance software links the substance master to the article-level bill of materials, so SVHC presence above 0.1% is known before the customer asks. Article 33 disclosures, SCIP notifications and the 45-day consumer clock all run from the same record, with full audit history.
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