REACH and RoHS: The Compliance Bar for Chemicals in Hygiene Products Is Rising

I. REACH SVHC Notification Obligations: Responsibility Transmission from Chemicals to Finished Products

REACH (Regulation on Registration, Evaluation, Authorization and Restriction of Chemicals) is the EU's core chemical control regulation, built on the principle of "no data, no market." For everyday consumer goods like hygiene products, the most direct compliance requirement comes from the SVHC (Substances of Very High Concern) Candidate List.

Under REACH, if a product contains any SVHC substance and meets two conditions — the SVHC content exceeds 0.1% (by weight) and the total annual export volume of that substance to the EU exceeds 1 ton — the manufacturer or importer must notify the European Chemicals Agency (ECHA). The SVHC list currently covers hundreds of substances and is updated twice yearly on average, continuously adding new restricted substances.

How does this requirement transmit through the hygiene products supply chain? When raw materials — such as SAP resins, nonwovens, adhesives, or printing inks — contain SVHC substances, suppliers must pass component information downstream, with finished product manufacturers ultimately bearing the notification obligation. Voluntary certification schemes like the Nordic Ecolabel have explicitly banned SVHC Candidate List substances in certified products — meaning the market bar is rising even before legislation mandates it.