SVHC: Importers Face New Customs Requirements

In the future, importers who wish to introduce products containing SVHCs must record the presence of such chemicals in customs documents. The EU Commission has required this information since October 1, 2019 for materials contained in the REACH Authorization List (Annex XIV).

According to Miquel Aguado-Monsonet of the Directorate- General for Internal MarketIndustry, Entrepreneurship and SMEs (GD GROW), the EU also plans to include chemicals covered by Annex XVII of REACH (restriction of certain hazardous substances, mixtures, and articles for manufacture, marketing, and use in the European market) in its TARIC system by the end of the year.

TARIC (Integrated Tariff of the European Communities) is the uniform customs tariff of the European Union. Its core is a multilingual database that stores the definition of individual customs rates and trade measures. All articles are classified by a TARIF code. Merchants use TARIC to see an overview of what they must consider when importing items into and exporting items out of the EU.

Nevertheless, it has been difficult for customs authorities using the TARIC codes to recognize the presence of certain SVHCs in articles – given that several chemicals can be hidden within one code. That’s why the EU wants to assign a specific code to each chemical and chemical group. That’s what Katja vom Hofe, chair of the ECHA Enforcement Forum stated at an event held by Chemical Watch.

The EU measure (Measure 13: Improving Enforcement) is part of an initiative aimed at better integration of REACH into customs regulations. Multiple projects in the EU are currently running that relate to REACH, customs, and enforcement. A 16-month study that will begin soon will analyze the integration of REACH into EU customs procedures. The ECHA recently published a report on a pilot project of the enforcement forum. The authors state that almost all the products inspected lacked information on SVHCs and that 12% of the items contained SVHCs.

In March, the national enforcement agencies in 16 member states began to inspect imported goods to find hazardous chemicals. A final report is expected in mid-2020.

Ursula von der Leyen, the new president of the European Commission, has also included customs protections in her mandate. In her Agenda for Europa published this summer, Dr. von der Leyen proposed a comprehensive and integrated set of measures to improve customs risk management and to support more-effective controls by member states (page 20).

We are familiar with the laws surrounding the use of SVHCs. Please contact us at

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