New REACH Candidate List Additions and the Upcoming Recast: What Manufacturers Need to Know

If you manufacture or sell products in the European Union, staying ahead of REACH compliance requirements is essential. The latest update to the Candidate List of Substances of Very High Concern (SVHCs) introduces new regulatory challenges, while discussions around a REACH “recast” suggest broader changes are coming.

Here’s what has changed, how it affects manufacturers and suppliers, and what steps businesses should take to stay compliant.

REACH Candidate List Updates and Their Impact

The European Chemicals Agency (ECHA) updates the Candidate List of SVHCs twice a year, typically in January and June. These updates are significant because they add new substances that may eventually require authorization for continued use.

Manufacturers and suppliers must assess whether any newly added SVHCs are present in their products above the 0.1% weight-by-weight (w/w) threshold at the article level. If they are, companies are legally required to disclose this information to ECHA, notify customers, and update safety data sheets accordingly.

While these updates generally follow a biannual schedule, an irregular addition occurred in November 2024 due to a missed substance. This highlights the need for companies to stay vigilant, as regulatory changes can happen outside of expected timeframes.

January 2025 SVHC Update: Five New Additions and One Revision

On January 21, 2025, ECHA officially added five new substances to the Candidate List and updated one existing entry, bringing the total to 247 substances.

Newly Added Substances

Octamethyltrisiloxane (EC 203-497-4, CAS 107-51-7) Commonly used in cosmetics, personal care products, polishes, waxes, and cleaning agents. Classified as very persistent and very bioaccumulative (vPvB).

O,O,O-triphenyl phosphorothioate (EC 209-909-9, CAS 597-82-0)
Used in lubricants, hydraulic fluids, and metalworking fluids. Identified as a persistent, bioaccumulative, and toxic (PBT) substance.

Reaction mass of triphenylthiophosphate and tertiary butylated phenyl derivatives (EC 421-820-9, CAS 192268-65-8)
Found in hydraulic fluids, lubricants, and greases, as well as metalworking fluids. This substance is not currently registered under REACH but was added to prevent regrettable substitution.

Perfluamine (EC 206-420-2, CAS 338-83-0) Commonly used in manufacturing electrical and optical equipment, machinery, and vehicles. Classified as very persistent and very bioaccumulative (vPvB).

6-[(C10-C13)-alkyl-(branched, unsaturated)-2,5-dioxopyrrolidin-1-yl] hexanoic acid (EC 701-118-1, CAS 2156592-54-8)
Present in hydraulic and metalworking fluids and lubricants. Classified as toxic for reproduction.

Updated SVHC Entry

Tris(4-nonylphenyl, branched and linear) phosphite (TNPP) (group)
Previously listed on the Candidate List, but now officially recognized for its endocrine-disrupting properties. TNPP is often found in polymers, adhesives, sealants, and coatings.

These substances may eventually move to the REACH Authorization List, requiring companies to apply for permission from the European Commission if they wish to continue using them.

Compliance Obligations for Manufacturers and Suppliers

With the Candidate List now containing 247 substances, companies need to ensure compliance by determining whether any of these newly added or updated SVHCs are present in their products. If so, companies are legally required to:

• Notify ECHA if SVHCs exceed the 0.1% (w/w) threshold.
• Inform customers and consumers about the presence of these substances.
• Update safety data sheets to reflect new regulatory requirements.

Non-compliance can result in supply chain disruptions, financial penalties, and reputational damage. Businesses that fail to assess their material compositions in time may face last-minute data collection efforts or the need for costly material substitutions.

Upcoming REACH Recast and Its Implications

Beyond the Candidate List updates, a broader REACH reform is in progress. A first proposal for a REACH recast is expected by the end of 2025, with potential significant impacts on substance registration, restriction, and authorization processes.

While details remain uncertain, key areas under discussion include:

• Changes to the registration process to align with the “one substance, one assessment” principle, aimed at improving transparency and efficiency.
• A potential overhaul of restriction and authorization mechanisms, which could either streamline or significantly alter current regulatory requirements.

The timeline for the REACH recast is not yet confirmed, but it has been prioritized by the Danish Presidency of the EU Council in the second half of 2025. Manufacturers should closely monitor these developments and prepare for possible rapid regulatory changes.

How Businesses Should Prepare for REACH Changes

1. Assess Your Supply Chain and Materials
   Companies should immediately review their products and materials to identify any newly listed SVHCs or substances likely to face stricter regulation under the upcoming REACH recast. Suppliers should be contacted to confirm the presence of these substances.

2. Centralize Data Collection and Regulatory Tracking
   Automated compliance solutions can help track regulatory changes, manage supplier documentation, and flag substances that may require future authorization. Businesses should ensure they have up-to-date safety data sheets and supplier declarations.

3. Monitor Legislative Developments
   Since the REACH recast is still evolving, staying engaged with regulatory news, industry associations, and compliance updates is critical. Manufacturers should attend relevant webinars and ensure compliance teams are prepared for potential changes in restriction and authorization procedures.

4. Evaluate Alternative Materials and Compliance Solutions
   If any of the newly added SVHCs or other high-risk substances are present in products, companies should explore alternative materials early to avoid disruption. Assessing compliance software that tracks SVHCs across multiple product lines can also be beneficial.

Final Thoughts: Stay Ahead of REACH Compliance Risks

The REACH Candidate List will continue to expand, and the upcoming recast may significantly alter how chemicals are regulated in the EU. Companies that track these developments and integrate compliance into their supply chains now will be better positioned to adapt.

Proactive action is essential. Businesses should review their material compositions, engage with suppliers, and ensure they are prepared for evolving regulatory requirements.

If your company relies on any of the newly listed SVHCs, now is the time to assess compliance strategies and evaluate potential material substitutions to avoid future market restrictions.

Reach out to our compliance expert at Acquis today