What to Re-Ask Suppliers After a REACH Candidate List Update
Founder & CEO Published Oct 16, 2026
When ECHA adds substances to the REACH Candidate List, every supplier declaration that names an older list version becomes stale. You do not need to re-ask every supplier for every part. You need to re-ask three groups:
- Suppliers whose declaration names no list version. You cannot tell what they checked.
- Suppliers whose declaration names an older version, starting with parts made of materials where the new substances are likely to appear.
- Suppliers who declared an SVHC present, so you have current data for your customers and their SCIP notifications.
Where you hold a full material declaration for a part, you can usually screen it against the new entries yourself, without asking anyone.
Here is where the list stands today. ECHA’s Candidate List table shows 253 entries, last updated on 4 February 2026. ECHA states that no new SVHC proposals were submitted during 2026, and that it expects the next update in June 2027. So a declaration against the 253-entry list is current for the EU today. Any declaration against an older EU list is not.
How do Candidate List updates work?
A substance gets onto the Candidate List through a public process set out in REACH Articles 57 and 59.
- A member state or ECHA prepares a dossier showing the substance meets the SVHC criteria. These include carcinogenic, mutagenic or toxic for reproduction, persistent and bioaccumulative, or an equivalent concern such as endocrine disruption.
- ECHA runs a 45-day public consultation.
- If no comments come in, the substance is listed. If comments come in, ECHA’s Member State Committee decides. If the committee cannot agree unanimously, the Commission decides.
- ECHA publishes the updated list. The supply chain duties start on that day.
ECHA usually publishes updates in batches, most often in January and June. In 2024 and 2025 there were three updates each year. In 2026 there has been one so far. The recent history:
| Update | Entries after update | Added |
|---|---|---|
| January 2025 | 247 | Five entries |
| June 2025 | 250 | Three entries |
| November 2025 | 251 | One entry |
| 4 February 2026 | 253 | n-hexane, and bisphenol AF and its salts |
| Next expected | June 2027, per ECHA | Not yet known |
The entry count is not the substance count. Some entries are groups. The bisphenol AF entry alone covers the parent substance plus several salts and reaction products.
You can see what is coming. ECHA’s registry of SVHC intentions lists substances that member states plan to propose. A substance usually sits there for months before it reaches the list. Check it every quarter, and you will rarely be surprised.
What changes for declarations when the list updates?
Three things change on the day of publication.
The Article 33 duty applies at once. Any supplier of an article that contains a newly listed substance above 0.1% w/w must tell its customers. There is no grace period. Since the 2015 O5A ruling, that threshold applies to each component article, not to the finished product.
Old declarations stop proving anything about the new substances. A declaration against the 251-entry list says nothing about n-hexane or bisphenol AF. It is still true for the substances it covered. It is just incomplete.
Deadlines start for EU producers and importers. Under Article 7(2), an EU producer or importer must notify ECHA within six months if a newly listed substance is in its articles above 0.1% and above one tonne a year in total. For the February 2026 additions, that deadline was 4 August 2026. EU suppliers must also update their SCIP notifications under the Waste Framework Directive. Your EU customers need your data to do both, which is why their requests arrive soon after each update.
Customers also re-ask on their own schedule. BOMcheck tells suppliers to update part-level REACH declarations every six months. Viasat tells its suppliers the list is updated about every six months and that answers must track it. Some customers send a fresh request after every update whether or not your parts are likely to be affected.
Which suppliers should you re-ask?
Start by sorting your existing declarations. This table works for most supply bases.
| What you hold for the part | Action after an update | Priority |
|---|---|---|
| A declaration with no list version or date | Re-ask now, whatever the update | Highest |
| A blanket supplier letter, not tied to part numbers | Re-ask for a part-level declaration | Highest |
| A part-level declaration against an older list, for a material likely to contain the new substances | Re-ask now | High |
| A part-level declaration against an older list, for a material unlikely to contain them | Re-ask in your next scheduled cycle | Medium |
| A declaration that lists an SVHC as present | Re-ask, to confirm the full current list | Medium |
| A full material declaration with CAS numbers | Screen it yourself against the new entries | Low, no supplier contact |
| A declaration already against the current list | Nothing | None |
The “likely material” test is where you save the most work. Read what the new substances are used for. ECHA publishes a support document for each entry that describes its known uses. For the February 2026 batch:
- Bisphenol AF is used as a curing agent in fluoroelastomers. Re-ask suppliers of O-rings, seals, gaskets, and other fluoroelastomer parts.
- n-hexane is a solvent. Re-ask suppliers of solvent-based adhesives, coatings, and inks, and parts where those are applied.
A re-ask of five gasket and adhesive suppliers is a much smaller job than a re-ask of 300 suppliers. It also gives you the answers your customers are most likely to ask about.
The table assumes your customers accept a targeted approach. Some do not. If a customer contract requires a declaration against the current list for every part, you re-ask everyone on that customer’s parts. Read each customer’s terms before you plan the round.
How do you track list versions per part?
Keep one row per part and supplier. The list version belongs in its own field, not buried in a PDF file name.
| Field | Example |
|---|---|
| Manufacturer part number | 12345-678 rev B |
| Supplier | The manufacturer, not the distributor |
| Declaration date | 12 March 2026 |
| EU list version | 253 entries, 4 February 2026 |
| UK list version | Stated, or “not stated” |
| Result | No SVHC above 0.1%, or the SVHCs present |
| SVHCs present | Name, CAS number, location in the part |
| Material notes | Contains fluoroelastomer seal |
| File location | Link to the signed declaration |
| Status | Current, stale, or missing |
Then set one reference value for the current list: 253 entries, 4 February 2026. Any row with an older version, or no version, is stale. When the next update lands, change the reference value once. Every row below it now shows whether it needs a re-ask. Filter the stale rows by material notes, and you have your re-ask list.
Two habits keep this clean. Record the list version that the declaration states, not the date you received it. A declaration sent to you in May 2026 can still name a 2023 list. And keep the old declaration when a new one arrives. An auditor may ask what you knew at the time you answered your customer.
What about the UK REACH list?
UK REACH runs its own Candidate List, kept by the Health and Safety Executive. The two lists have drifted apart. On 15 June 2026, HSE added 15 substances to the UK list. They were already on the EU list. That was the UK’s first substantive update since the end of the Brexit transition.
So in 2026, the UK list changed while the EU list did not. A request that just says “REACH” is now ambiguous. In your supplier request, name the list you want: EU, UK, or both, each with its version. If you ship to UK customers, track the UK version in its own field.
What should you do while the EU list is quiet?
ECHA does not expect another EU update until June 2027. That gives you a rare window to fix the backlog without new substances piling on.
- Find every declaration with no list version. Re-ask those suppliers for a part-level declaration against the 253-entry list.
- Find every declaration older than 4 February 2026. Re-ask, starting with fluoroelastomer, adhesive, and coating parts.
- Replace blanket letters on parts that go to your strictest customers.
- Add the list version field to your tracker if it is not there.
- Check the registry of intentions each quarter, so you know which materials the June 2027 batch may touch.
Do the cleanup now and the next update becomes a short, targeted re-ask. For what a good declaration must contain, see what a REACH SVHC declaration from a supplier should include. For suppliers who stop answering, see how to follow up with unresponsive suppliers.
TL;DR
How often does the Candidate List update?
Usually twice a year, in January and June, with an extra update in some years. In 2026 there was one update, on 4 February. ECHA expects the next in June 2027.
How many entries does the list have now?
253, as of 16 October 2026, per ECHA’s Candidate List table.
Do I have to re-ask every supplier after an update?
Not always. Re-ask suppliers with no list version first, then older declarations for materials likely to contain the new substances. Follow your customers’ terms where they demand a full refresh.
Does the UK list match the EU list?
No. HSE added 15 substances to the UK list on 15 June 2026. Ask suppliers to name which list they declared against.
Sources
- ECHA Candidate List table. The authentic list. States the 4 February 2026 update and the June 2027 outlook.
- ECHA registry of SVHC intentions. Substances proposed for future listing.
- REACH, Regulation (EC) 1907/2006, consolidated text. Articles 7(2), 33, 57 and 59.
- CJEU, Case C-106/14 (O5A). The 0.1% threshold applies to each component article.
- Directive (EU) 2018/851. The SCIP duty under the Waste Framework Directive.
- HSE bulletin on the UK REACH Candidate List, June 2026. The 15 UK additions.
- SGS on the February 2026 update and TÜV SÜD on the January 2025 list. Secondary summaries of past updates.
Bridgecurrent sends these re-ask requests from your own email, follows up, finds a better contact when someone goes quiet, and sends back any declaration that fails the check. See pricing.