REACH Candidate List at 253 Entries: A BOM Screening Workflow

  News     |      2026-09-07 14:53

As of 7 September 2026, ECHA’s authentic Candidate List contains 253 entries. The most recent update was published on 4 February 2026, when ECHA added n-hexane and a group entry for 4,4′-[2,2,2-trifluoro-1-(trifluoromethyl)ethylidene]diphenol and its salts.

For manufacturers selling products into the EU, the practical task is broader than searching a flat BOM for two chemical names. Candidate List entries can cover groups, individual members, salts, anhydrous forms and hydrated forms. Complex products must also be assessed at the level of their constituent articles. A defensible review therefore connects product structure, material and formulation data, supplier evidence, targeted testing and the appropriate REACH or SCIP action.

The latest Candidate List snapshot

n-Hexane, EC 203-777-6 and CAS 110-54-3, was identified for specific target organ toxicity after repeated exposure under Article 57(f) for human health. ECHA lists examples including formulation, polymer processing, coatings and cleaning agents. A product review should therefore look beyond intentionally added substances in the final material and consider processing chemicals, cleaners, coating systems and supplier formulation gaps.

The second entry covers Bisphenol AF and its salts. It was identified as toxic for reproduction under Article 57(c). This is a group entry without one EC or CAS number that represents its full scope. ECHA’s entry details identify Bisphenol AF, salts and other members, while the news release notes uses such as process regulators and cross-linking agents. Elastomers, specialised polymers, resins and coating systems may require a member-level supplier check rather than a single-CAS search.

The figure 253 refers to entries, not a closed checklist of 253 CAS numbers. One entry can cover several substances. ECHA also states that an entry covers corresponding anhydrous and hydrated forms. Screening logic should accommodate names, identifiers, synonyms, group membership and formulation information.

Candidate listing is not a blanket ban

The Candidate List is distinct from the REACH Authorisation List in Annex XIV and the restrictions in Annex XVII. Inclusion can create immediate communication and information-management duties and may be followed by future authorisation work, but it does not by itself mean that every use is prohibited. The applicable response depends on the substance, concentration, annual tonnage, use and supply-chain role.

  • REACH Article 33: when a Candidate List substance is present above 0.1% w/w in an article, the supplier must provide recipients with enough available information for safe use, including at least the substance name. A consumer request must be answered free of charge within 45 days.
  • REACH Article 7(2): an EU producer or importer assesses both the concentration threshold above 0.1% w/w and the aggregate quantity above one tonne per year in the relevant articles. Where the conditions apply, notification is generally due within six months of listing. Exemptions such as prior registration for that use or the ability to exclude exposure require supporting evidence.
  • SCIP: EU producers, assemblers, importers and certain distributors placing affected articles on the EU market may need to submit article identity, substance location, concentration range, material category and safe-use information. ECHA excludes retailers that supply directly and exclusively to consumers from the listed submission duty.
  • Substances and mixtures: Candidate listing may also affect safety data sheet obligations. These should be managed separately from the Article 33, Article 7 and SCIP routes for articles.

A proposed SCIP reform is still moving through the legislative process. Commission proposal COM(2025) 986 would discontinue new SCIP submissions, but EUR-Lex still lists procedure 2025/0394/COD as ongoing on 7 September 2026. A proposal is not current law. Companies should not treat the existing duty as repealed unless and until the amending directive is adopted and takes effect under its final terms.

Why article-level BOM structure matters

In case C-106/14, the Court of Justice confirmed that the 0.1% w/w threshold applies to the relevant constituent article in a complex product. It should not be diluted by using the mass of the entire assembled product. Screws, cables, connectors, housings, seals and printed circuit boards that qualify as articles before assembly generally retain that identity after assembly.

A screening-ready product record should contain at least five connected layers:

  1. Product: model, variant, destination market, manufacturer and EU supply-chain role;
  2. Constituent article: identifiable component, subassembly and number of occurrences;
  3. Material or mixture: substrate, coating, adhesive, ink, lubricant, sealant and relevant processing residue;
  4. Substance: name, EC/CAS, synonym, Candidate List entry or group member, concentration range and location;
  5. Evidence: supplier declaration, SDS, formulation disclosure, test report, version date, covered part numbers and validity.

A declaration that says only “REACH compliant” or “no SVHC” may be insufficient if it does not identify the Candidate List version, material or part scope, threshold basis and issuing supplier. Evidence should be tied to the exact BOM revision and supply source.

A six-step screening workflow

  1. Freeze the regulatory baseline. Record the screening date, Candidate List count and authentic source. For this review, the baseline is 7 September 2026 and 253 entries.
  2. Build the article tree. Expand the product BOM to constituent articles and materials. Normalise part numbers, revisions, suppliers and manufacturing sites so that aliases do not hide gaps.
  3. Expand the substance dictionary. Match EC/CAS numbers, names, synonyms, salts, hydrated forms and group members. Use member lists and formulation evidence for entries that have no single identifier.
  4. Prioritise by use. For n-hexane, review cleaners, coatings, polymer processing and formulation. For Bisphenol AF and its salts, examine cross-linking systems, elastomers and specialised polymers.
  5. Resolve unknowns. Request article-level supplier declarations and concentration ranges. Use targeted analytical testing for high-risk materials or evidence gaps instead of applying one generic scan to every product.
  6. Route each confirmed hit. Assess Article 33 communication, consumer-response readiness, Article 7 notification, SCIP submission, SDS implications and future authorisation or restriction monitoring as separate actions.

Use testing as evidence, not as a substitute for the supply chain

The Candidate List spans different chemical classes and analytical methods, while group entries can contain multiple members. Laboratory testing can verify a particular material, challenge a high-risk supplier statement, investigate a formulation change or close a defined data gap. A single broad test on the assembled product, however, does not automatically demonstrate that every constituent article is free from every Candidate List entry.

A targeted plan should identify the sample part and lot, the relevant substance or group, sampling location and homogeneous material, the analytical method, and how detection and quantification limits relate to the 0.1% w/w assessment. Results must be mapped back to a specific constituent article. A negative result also needs a defined scope and should not be carried indefinitely across suppliers, formulations or product revisions.

How Qianxin can support screening readiness

For a defined product structure, destination market and written scope, Qianxin can support material and component grouping, risk-based identification of Candidate List uses, targeted chemical-testing requirements, sample-to-BOM consistency checks, and a preliminary completeness review of supplier declarations, SDSs and test reports. The responsible economic operator retains ownership of final Article 33, Article 7, SCIP, authorisation and restriction applicability decisions.

This article reflects public ECHA and EUR-Lex information available on 7 September 2026. It provides general information and is not a substitute for product-specific legal advice or a final conformity assessment.

Official Sources