How do you find every product a restricted substance affects?
Summary
Tracing a newly restricted substance takes 5 steps: confirm the listing, search SDS section 3, compare concentrations, map customers, then decide notices and SDS revisions. Under EU REACH, Candidate List duties for articles start above 0.1% w/w, and each Annex XVII restriction sets its own limit (Regulation 1907/2006, Articles 33, 67). Unread compositions stay unconfirmed, not cleared.
A supplier of an article containing a Candidate List substance above 0.1% w/w must give the recipient enough information for safe use, as a minimum the substance name (Regulation 1907/2006, Article 33).
Once a restriction has been imposed, suppliers must update the safety data sheet without delay and send the revision to every recipient supplied in the preceding 12 months (Regulation 1907/2006, Article 31).
Producers and importers of articles must notify ECHA no later than six months after a substance is listed, when it is above 0.1% w/w and over 1 tonne per producer or importer per year (Regulation 1907/2006, Article 7).
In the US, significant new hazard information must be added to the safety data sheet within three months of becoming aware of it (OSHA, 29 CFR 1910.1200, 2026).
This method follows EU REACH and notes where UK REACH and the US Hazard Communication Standard differ. It does not cover authorisation applications under REACH Annex XIV or national lists in other jurisdictions, which each need their own entry text.
What do you need before tracing a restricted substance through your products?
Before tracing a restricted substance through your products, you need four things in hand: the exact listing entry, the current safety data sheet (SDS) for every product, a record of who received or uses each product, and a written rule for what counts as unconfirmed.
The listing entry: substance name, EC and CAS numbers, the list, the inclusion date and, for a REACH Annex XVII restriction, the entry's conditions and limit. The EU and GB lists are separate: HSE describes the UK REACH Candidate List as "a list of SVHCs identified in accordance with Article 59 of UK REACH" (HSE, 2026).
The SDS set: the latest revision of each product SDS and each raw material SDS, since your SDS discloses only what its inputs disclosed.
The customer record: who received each product in at least the last 12 months, the period that REACH revision duties reach (Regulation 1907/2006, Article 31), plus product use records showing where it is used.
The unconfirmed rule: a product whose composition has not been read stays unconfirmed, never not affected by default.
How do you trace a restricted substance to products and customers step by step?
You trace a restricted substance to products and customers in five steps, one action each, recorded in one table with a row per product.
Confirm the listing. Record the entry, the inclusion date and any conditions or derogations. If you produce or import articles, note the notification date six months after inclusion (Regulation 1907/2006, Article 7).
Search SDS section 3. Look for the substance name, EC number and CAS number in every product SDS and every raw material SDS. Record each SDS revision date.
Compare concentrations. Take the exact value, or the upper end of a range, and compare it with the trigger for that list and product form. For articles, compare per article, not per assembled product.
Map customers. For each affected or unconfirmed product, list every recipient in the last 12 months and every current user found in product use records.
Decide notices and SDS revisions. Mark each row: inform recipients, revise the SDS, ask the supplier for the composition, or no action when the read composition is below the trigger.
Which SDS sections show whether a product contains the restricted substance?
SDS section 3, composition and information on ingredients, shows whether a product contains the restricted substance, with section 15 and section 16 as cross-checks. For mixtures, section 3 must give the product identifier, the concentration or concentration range and the classification for at least the substances that REACH Annex II, point 3.2.1 or 3.2.2, requires (Regulation 2020/878, Annex, 2020).
For a classified mixture, that list includes hazardous substances at or above their cut-off values, for example 0.1% for carcinogenicity category 1A, 1B and 2 and for reproductive toxicity (Regulation 2020/878, Annex, Table 1.1). It also includes, from 0.1%, PBT and vPvB substances and Candidate List substances listed for reasons other than those hazards, such as endocrine disrupting properties (Regulation 2020/878, Annex, point 3.2.1).
Section 15 should name restrictions under REACH Title VIII that apply to the product. Section 16 should show where a revised SDS changed. An absence in section 3 is not proof of absence: a substance below its listing value need not appear, and an SDS dated before the listing cannot reflect it.
What concentration makes a product affected by a restricted substance listing?
The concentration that makes a product affected depends on the list and the product form: for a REACH Candidate List substance, 0.1% w/w is the trigger in articles and, for non-gaseous mixtures, the point from which a classified mixture's SDS must list it and an unclassified mixture needs an SDS on request, while an Annex XVII restriction applies at the limit and conditions in its own entry (Regulation 1907/2006, Articles 31, 33, 67; Regulation 2020/878, Annex).
For articles, the supplier must inform recipients when the substance is above 0.1% w/w (Regulation 1907/2006, Article 33). In a product made of several articles, the Court of Justice held that the 0.1% applies to each constituent article (CJEU, 2015, C-106/14). For an Annex XVII restriction, REACH states that the substance "shall not be manufactured, placed on the market or used unless it complies with the conditions of that restriction" (Regulation 1907/2006, Article 67).
The check table below decides, for each product, whether the listing makes it affected or leaves it unconfirmed and what to do next.
Check | Affected | Unconfirmed and what to do |
|---|---|---|
Listing entry | Entry, inclusion date and conditions recorded | Entry text not read: get the official entry before classing any product |
SDS section 3 | Substance named by name, EC or CAS number | SDS dated before the listing, or trade names only: ask the supplier for a written statement on the substance |
Concentration in an article | Above 0.1% w/w in that article (Regulation 1907/2006, Article 33) | Only the assembled product's total is known: get each component article's weight and content (CJEU, 2015) |
Concentration in a mixture | 0.1% by weight or more in a non-gaseous mixture: listed in SDS section 3 if the mixture is classified (Regulation 2020/878, Annex, point 3.2.1), SDS on request if not (Regulation 1907/2006, Article 31); or at the Annex XVII entry's own limit | Range crosses the trigger: treat the upper end as affected until the supplier gives a value |
Customers | Every recipient in the last 12 months listed (Regulation 1907/2006, Article 31) | Delivery or use record missing: list the customer as unconfirmed and ask what they hold |
The range row decides most cases: when an SDS range crosses the trigger, treat the product as affected until the supplier states a lower value; REACH does not set this rule, it keeps the trace on the safe side. A product is not affected only when its read composition is below the trigger.
Which customers need to hear first after a substance is restricted?
The customers who need to hear first after a substance is restricted are those whose use the restriction condition now prohibits, then recipients of affected articles, then recipients of affected mixtures in the last 12 months (Regulation 1907/2006, Article 31), then customers holding unconfirmed products. The order follows what each must do: stop a use, pass information on, or update documents.
Prohibited use: an Annex XVII entry can bar a use outright, so those customers need notice before their next order.
Article recipients: the Article 33(1) duty to inform has no tonnage threshold and applies to every recipient of an article above 0.1% w/w (Regulation 1907/2006, Article 33). A consumer who asks must receive the information free of charge within 45 days of the request (Regulation 1907/2006, Article 33). Since 5 January 2021, article suppliers must also send the Article 33(1) information to ECHA (Directive 2008/98/EC, Article 9).
Mixture recipients: the revised SDS goes to all recipients supplied in the preceding 12 months (Regulation 1907/2006, Article 31).
Unconfirmed customers: ask which products and lots they hold, and record the answer in the trace table.
When does a restricted substance listing require an SDS revision?
A restricted substance listing requires an SDS revision without delay once a restriction has been imposed, and also when the listing brings new hazard information that may affect risk management measures (Regulation 1907/2006, Article 31). REACH states: "Suppliers shall update the safety data sheet without delay on the following occasions", including "once a restriction has been imposed" (Regulation 1907/2006, Article 31).
The revised SDS carries the label "Revision: (date)" and goes free of charge to every recipient supplied in the preceding 12 months (Regulation 1907/2006, Article 31). Section 15 must name the restriction and section 16 must show what changed (Regulation 2020/878, Annex, sections 15 and 16).
A Candidate List entry has a separate effect on the substance itself: a supplier must provide an SDS for a substance included in the list, even one not classified as hazardous or as PBT or vPvB (Regulation 1907/2006, Article 31). In the United States, the Hazard Communication Standard requires significant new hazard information to be added to the SDS within three months (OSHA, 29 CFR 1910.1200, 2026). Check the technical data sheet in the same pass and revise it if it names the substance or a use the restriction removes.
When should a regulatory specialist review a restricted substance trace?
A regulatory specialist should review a restricted substance trace when the listing entry has derogations or use-specific conditions, when a product is a complex article made of several components, when you sell the same product in the EU and Great Britain, or when a supplier will not disclose the composition. Each turns a lookup into a legal reading.
A specialist also matters when you plan to rely on an exemption. REACH lets a producer or importer of articles skip the ECHA notification where it can exclude exposure to humans or the environment during normal or reasonably foreseeable use, including disposal, but it must then supply instructions to the recipient (Regulation 1907/2006, Article 7). That judgment needs documented exposure evidence. Notification is also not required where the substance has already been registered for that use (Regulation 1907/2006, Article 7).
Lubinpla runs this kind of impact scope check on your own SDSs, selected in the data room by tag and file name, and on your product use records: it lists the products and customers the substance reaches, sets the response order and whether SDSs and TDSs need revision, leaves products it could not look up as unconfirmed, and relies on your team to bring in the listing change.
Common mistakes when tracing a restricted substance
The most common mistakes when tracing a restricted substance come from treating missing information as a negative result.
Treating Candidate List inclusion as a ban. Inclusion starts information and notification duties. A ban comes from an Annex XVII restriction or from Annex XIV authorisation.
Recording a product as not affected because its SDS does not name the substance. An old SDS or a substance below its listing value can hide it.
Comparing the whole product's content when it is made of several articles. The 0.1% applies per constituent article (CJEU, 2015, C-106/14).
Using the lower end of a concentration range. Use the upper end until the supplier states a value.
Searching only your own SDSs. Raw material SDSs show what your formulation inherited.
Stopping at current customers. REACH revision duties reach everyone supplied in the preceding 12 months (Regulation 1907/2006, Article 31).
Checking only one jurisdiction. The EU and UK REACH Candidate Lists are separate lists (HSE, 2026).
Frequently asked questions
Does the 0.1% article trigger have a tonnage threshold?
The duty to inform recipients under REACH Article 33 has no tonnage threshold: it applies at any volume once the substance is above 0.1% w/w in the article. The ECHA notification adds a second condition, over 1 tonne per producer or importer per year (Regulation 1907/2006, Article 7).
Does a listing on the EU Candidate List also cover Great Britain?
An EU Candidate List entry does not cover Great Britain, which keeps its own list: HSE publishes the UK REACH Candidate List of SVHCs identified under Article 59 of UK REACH (HSE, 2026). Check the substance against both lists, and keep separate trace tables when the inclusion dates differ.
How long should the trace table be kept?
REACH requires each manufacturer, importer, downstream user and distributor to keep the information needed for its duties for at least 10 years after it last supplied or used the substance or mixture (Regulation 1907/2006, Article 36). Keep the trace table and the notices for the same period.
What if a supplier refuses to disclose the composition?
Keep the product unconfirmed and record the request, its date and the reply. Ask for a written statement on the one substance and its concentration band instead of the full formula, which is a narrower request than disclosing the whole composition.