EU REACH Compliance Guide: SVHC Declaration for Amazon Sellers (2026)

If you sell products on Amazon EU marketplaces, you have probably received a notification asking for a REACH SVHC declaration. If you ignored it, your listings may already be gone. In 2026, Amazon is enforcing REACH compliance aggressively, and the January 2027 deadline for full supply chain transparency is approaching fast.

The problem? Most sellers have no idea what REACH is, what an SVHC is, or how to get their products tested. They assume their supplier will handle it, or that it doesn't apply to them. That assumption is costing sellers their accounts. Let me walk you through everything you need to know, step by step, so you can keep your EU listings alive and stay ahead of the regulators.

What is REACH and Why It Matters for Cross-Border Sellers

REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemicals. It is a comprehensive EU regulation (EC 1907/2006) that governs the production, import, and use of chemical substances. Enacted in 2007 and administered by the European Chemicals Agency (ECHA), it applies to virtually every product sold in the EU, whether it is a children's toy, a phone case, or a kitchen appliance.

For cross-border sellers, here is why REACH matters more than ever: Amazon has made REACH compliance a condition of selling on its EU marketplaces. If you cannot provide an SVHC declaration when asked, your listings will be removed. There is no appeal process that will save you if the documentation is missing. The same applies if you sell on other EU platforms like Cdiscount or bol.com — REACH enforcement is industry-wide.

I worked with a seller last year who lost 30 SKUs overnight because his silicone kitchen molds contained a phthalate that was added to the SVHC list in a routine ECHA update. He had no idea the list had changed. His supplier had used the same formulation for three years. Amazon flagged the product category, requested the declaration, and when he couldn't provide test reports, the listings were pulled. That seller lost approximately 18,000 euros in monthly revenue.

SVHC List: The Candidate List of Substances of Very High Concern

The SVHC Candidate List is the heart of REACH compliance. It is a publicly maintained list of substances that the ECHA has identified as causing serious harm to human health or the environment. These include carcinogens, mutagens, reproductive toxicants (CMRs), persistent bioaccumulative toxicants (PBTs), and endocrine disruptors.

As of 2026, the list contains over 240 substances, and it grows roughly twice a year. Common SVHCs that catch sellers off guard include:

• Phthalates (DEHP, DBP, BBP, DIBP): Found in PVC, soft plastics, and vinyl coatings. Extremely common in cheap consumer goods.
• Lead and lead compounds: Found in pigments, metal alloys, and solder. Even trace amounts can trigger a declaration requirement.
• Cadmium: Found in some pigments, batteries, and metal coatings.
• Formaldehyde: Found in adhesives, resins, and composite wood products.
• Bisphenol A (BPA): Found in polycarbonate plastics, epoxy resins, and thermal paper receipts.

SVHC Substance	Common Use	Risk Category	Threshold
DEHP (Phthalate)	PVC, soft plastics	Reproductive toxicant	0.1% w/w
Lead	Paints, metal alloys	Reproductive toxicant	0.1% w/w
Cadmium	Pigments, coatings	Carcinogen, mutagen	0.1% w/w
Formaldehyde	Adhesives, resins	Carcinogen	0.1% w/w
Bisphenol A	Polycarbonate plastics	Endocrine disruptor	0.1% w/w

How to Determine if Your Product Contains SVHCs

This is where most sellers freeze. You didn't formulate the product, you didn't choose the materials, and you probably don't have a chemistry degree. So how do you know what is in it? There are three practical approaches:

1. Request a Bill of Materials (BOM) from your supplier: Ask your factory for a complete BOM listing every material used in the product and its packaging. Cross-reference each material against the current SVHC list. If the supplier cannot provide a BOM, that is a red flag. A professional factory should have this on hand.
2. Obtain a material safety data sheet (SDS): For products that contain liquids, gels, or chemical mixtures (like cosmetics, cleaning products, or adhesives), request an SDS from your supplier. The SDS should list all hazardous components and their concentrations.
3. Send the product to a lab for SVHC testing: This is the most reliable method. An ISO 17025-accredited lab will test each material in your product against the full SVHC list. You will receive a test report that you can use for your Amazon declaration and your SCIP notification to ECHA.

The key insight: you do not need to know the chemistry yourself. You need to ask the right questions to your supplier and, when in doubt, send it to a lab. A $500 test is cheaper than losing your Amazon account.

One important note: if your product has multiple materials (for example, a kitchen utensil with a plastic handle and a stainless steel body), each material must be tested separately. The SVHC threshold of 0.1% applies to each homogeneous material, not the product as a whole.

REACH Testing Process and Cost Breakdown

Let's demystify the testing process. REACH SVHC testing is not a single test — it is a targeted analysis for specific substances in specific materials. Here is how it works:

1. Select a lab: Use an ISO 17025-accredited laboratory. TÜV, SGS, Intertek, and Eurofins are all reputable options. Make sure the lab is experienced with consumer product REACH testing.
2. Provide product samples: You typically need to send 2-3 units of the product. The lab will disassemble it and identify each homogeneous material.
3. Define the test scope: You can test for the full SVHC list or focus on the substances most likely to be present in your product's materials (risk-based screening). Full testing is more expensive but more defensible.
4. Receive the test report: The lab issues a formal report stating whether each tested SVHC is present above or below the 0.1% threshold. This report is your evidence of compliance.
5. Create the SVHC declaration: If no SVHCs are above 0.1%, you can declare the product is REACH-compliant. If any SVHC is above 0.1%, you must notify ECHA via the SCIP database and provide safety information to your downstream users and consumers.

Item	Estimated Cost (USD)	Timeline
SVHC Full List Testing (per material)	$150 – $400	2–4 weeks
SVHC Risk-Based Screening (per product)	$300 – $1,000	1–3 weeks
Full Product Testing (all materials)	$500 – $1,500	2–4 weeks
SCIP Database Notification Preparation	$200 – $600	1–2 weeks
Compliance Consulting (optional)	$200 – $500	1–3 days
Total Estimate (typical product)	$500 – $2,100	3–6 weeks

Costs vary based on the number of materials in your product, the complexity of the formulation, and whether you choose full-list testing or risk-based screening. For a simple single-material product like a silicone spatula, expect the lower end. For a multi-component product like a baby bottle with a plastic body, silicone nipple, and printed label, expect the higher end.

How to Upload REACH Declarations to Amazon

Amazon's compliance portal for REACH is integrated into Seller Central. When Amazon flags your product category for REACH compliance, you will receive a notification in your Account Health dashboard. Here is how to handle the upload:

1. Log into Seller Central and navigate to Account Health, then look for the "Product Compliance Requests" section.
2. Identify the affected ASINs: Amazon will list the specific products that require a REACH SVHC declaration. Click "Provide Documentation."
3. Upload your test report: The report must be from an ISO 17025-accredited lab and must clearly show that the product was tested for SVHCs. Amazon does not accept self-declarations without lab backing.
4. Upload your SVHC declaration: This is a signed document stating that, based on the test report, the product either does not contain SVHCs above 0.1% or lists the SVHCs that are present and the safety information provided to consumers.
5. Submit and wait for review: Amazon typically reviews REACH submissions within 5–14 business days. You will receive an approval or rejection notification.

Also note that if you sell on other EU platforms or via your own Shopify store, you may need to provide the same documentation to market surveillance authorities upon request. The documentation you prepare for Amazon can be reused for other compliance requests.

REACH vs RoHS vs Prop 65: What's the Difference

This is one of the most common questions I get from sellers. Three chemical regulations, all looking similar but covering different things. Here is a clear breakdown:

Regulation	Region	Scope	Key Requirement
REACH	EU	All products with chemical content	Declare SVHCs above 0.1% w/w
RoHS	EU	Electrical and electronic equipment	Restrict 10 hazardous substances below thresholds
Prop 65	California (USA)	Products sold in California	Provide warnings for listed carcinogens/reproductive toxicants

REACH covers the broadest scope. If your product contains any chemical substance — and all physical products do — REACH applies. RoHS only applies to electronic products and restricts a specific list of substances (lead, mercury, cadmium, etc.) in electronic components. If you sell a smart electronic device like a pet feeder with a Wi-Fi module, you will also need CE-RED certification in addition to REACH compliance.

California Prop 65 is a US state law that requires warning labels on products containing any of the 900+ chemicals on the Proposition 65 list. The thresholds are stricter than REACH, but the requirement is disclosure (a warning label), not necessarily reformulation. A product can be REACH-compliant but still require a Prop 65 warning, and vice versa.

The practical takeaway: if you sell in both the EU and California, you likely need to comply with all three. Start with REACH since it has the broadest scope, then layer on RoHS (if applicable) and Prop 65.

Key Takeaways