Q: When must a REACH SVHC declaration be updated?
The candidate list is amended periodically, so a declaration has a shelf life even if nothing in the product changed. A sound practice is to reissue it whenever the list changes, at least once a year, and whenever a material, dye, coating, lubricant or supplier changes. A declaration that does not state the list version it was assessed against cannot be checked.
If a newly listed substance is present above 0.1 percent in any article, you owe your customer the information needed for safe use, and the supplier must provide it within 45 days of the request. Articles placed on the EU market may also need to be notified to the SCIP database. The threshold applies per article, so a small slider and a long tape are judged separately.
Build the update into supplier review: collect declarations with the purchase order, log the list version, and flag the parts that rely on a declaration rather than a test. When a substance is added to the list, ask specifically about it rather than accepting a general statement of compliance.