REACH and the SVHC Candidate List: what the 0.1% threshold means for a coated magnet

What is the SVHC Candidate List

Regulation (EC) 1907/2006, known as REACH, maintains a list of substances of very high concern, abbreviated SVHC. This list is called the Candidate List because the substances placed on it are candidates for inclusion in Annex XIV of the regulation, that is, in the list of substances subject to the authorisation procedure.

This is the most commonly confused element of the whole mechanism: placing a substance on the Candidate List does not, by itself, ban its use or production. A ban, if it happens at all, is a separate and later step, concerning Annex XIV. The listing on the Candidate List alone triggers something else - information duties towards further links in the supply chain.

The Candidate List is updated regularly, and its current state is maintained and published by the European Chemicals Agency. We do not give the number of entries or the date of the last update here - this data changes more often than this text does, and checking the current list takes less time than making sure a number you have read is still current.

The 0.1% by weight threshold - calculated from what

The REACH information duty is triggered when a substance from the Candidate List is present in an article above the 0.1% by weight threshold. The key question, which in practice decides the outcome, is: 0.1% of what?

The answer is: of the mass of the article, and in the case of an article made up of several separate components - of the mass of that specific component which itself constitutes an article within the meaning of REACH, not of the mass of the whole. This distinction has practical significance and it is easy to ignore it by calculating the threshold in a more convenient but incorrect way.

Imagine the same amount of a given substance present in a thin magnet coating. Related to the mass of the coating alone - which is a small fraction of the mass of the whole magnet - it can easily exceed the 0.1% threshold. The same amount of substance related to the mass of the whole magnet, including the heavy core, will fit within the threshold with ease and give the impression there is no issue. The correct approach is to calculate the threshold from the mass of the coating as a separate component, not from the mass of the whole - because it is the coating, not the whole magnet, that carries the substance here.

In other words: the smaller and lighter a component is, in which a given substance occurs, the easier it is to exceed a threshold calculated from its own mass - and the more misleading it would be to dilute that result with the mass of the entire product.

A composite article: magnet, coating, adhesive, packaging

A neodymium magnet is not a uniform block of material, but an article made up of several components with different compositions and different masses. The base is a core made of NdFeB sinter, an alloy of neodymium, iron and boron. A protective coating is applied to the core - most often multilayer nickel plating in a nickel-copper-nickel arrangement, though zinc, epoxy or gold coatings are also found. When the magnet is fitted into a holder or another mechanical component, adhesive is added as well. On top of that, the magnet reaches the customer in packaging, which is itself subject to separate regulations.

Each of these components - core, coating, adhesive, packaging - has a different chemical composition and a different mass. It follows directly that the question 'does your magnet contain SVHC', asked without specifying which component is meant, has no single correct answer. A reliable answer breaks the question down into four separate checks, each of which calculates the 0.1% threshold from the mass of its own relevant component, according to the principle described above.

It is worth remembering here that packaging is subject to a different legal basis than the article itself - the regulation on packaging and packaging waste, where a separate threshold for heavy metals applies, expressed in milligrams per kilogram rather than in percentage by weight. Mixing these two legal regimes, just because both operate with a quantitative threshold, leads to incorrect conclusions.

Article 33 - the information duty towards the customer

Article 33 of the REACH regulation requires a supplier of an article containing a substance from the Candidate List above the 0.1% by weight threshold to provide the recipient with information sufficient for safe use of the article, including at least the name of that substance.

The way this duty is carried out differs depending on who the recipient is. Towards a professional recipient, that is, another business in the supply chain, the information is provided on the supplier's own initiative, without the need to be asked for it. Towards a consumer, the duty is triggered only on their explicit request - and in that case REACH sets a specific deadline for the answer: 45 days from receipt of such a request.

This distinction has practical significance for every company selling articles both to other businesses and directly to consumers - the manner and timing of providing the information differ in each of these two cases.

Which document does the customer get

In practice a customer may receive several different types of documents, depending on exactly what they want to confirm - and it is worth knowing how they differ, rather than treating them interchangeably.

A supplier's declaration is a written statement from the manufacturer or supplier, based on their knowledge of the article's material composition and on declarations received from their own raw material suppliers. It does not require laboratory testing - it is a statement of knowledge, not a measurement result.

A laboratory test report is a document confirming the material composition based on an actual analysis of a sample, carried out by an accredited laboratory. It answers the question about a specific, measured result, rather than a declaration based on material documentation.

A product data sheet is a descriptive document that gathers technical parameters and information on compliance with specific regulations in one place, usually addressed to the customer's purchasing department or quality control.

Which of these documents is the right one depends on where the person asking stands in the supply chain and exactly what they need for their own documentation - a supplier's declaration sufficient to meet the information duty under Article 33, or evidence based on a measurement.

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