REACH SVHC Candidate List 2026 Update: Pseudo-Boehmite, ATH and ZSM-5 Status Check

1. Why the 2026 REACH SVHC cycle matters to inorganic adsorbent buyers

Every January and every June the European Chemicals Agency (ECHA) updates the Candidate List of Substances of Very High Concern (SVHC) for Authorisation under Regulation (EC) No 1907/2006 (REACH). The June 2026 cycle added 8 new entries (ECHA press release of 25 June 2026, bringing the total to 251 entries as of the publication date) and the next dossier cycle closes on 28 February 2027. The candidate list is the upstream signal that drives two procurement risks you, the purchasing engineer, cannot delegate to the supplier: (a) whether the SDS Section 12 must be amended and (b) whether the EU Importer Article 33 communication to downstream professional users must trigger before the next shipment lands.

The 2026 cycle added several inorganic precursors, process residues, and trace-metal contaminants that appear at parts-per-million levels in technical-grade pseudo-boehmite, ATH, and ZSM-5. None of the three product families are SVHCs themselves (Annex IV or V exemptions), but their SDS Section 12 data and lot-specific trace-element certificate must align with the current candidate list thresholds before the goods clear customs.

2. The SVHC threshold mechanics: 0.1% w/w per article is the only number that matters

REACH Article 33(1) requires any supplier of an article containing an SVHC at greater than 0.1% weight-by-weight (w/w) to provide the recipient with safety information including the name of the SVHC at no charge. Article 7(2) requires the same supplier to notify ECHA if the SVHC content exceeds 0.1% w/w and the total quantity of the article placed on the EU market exceeds 1 tonne per year per importer. The 0.1% w/w threshold is per article, not per shipment, not per batch, and not per product line.

For inorganic oxide adsorbents this threshold creates a de-facto upper bound on certain trace elements. Boron (as borates or boric acid, EC 233-139-2 / 234-343-4) would trigger notification if the pseudo-boehmite gel retains >1000 mg/kg boron from the peptization acid (legacy Chinese processes used H3BO3 before switching to HCl, HNO3, or formic acid — see EN 1842:2009). Lead (Pb, EC 231-100-4, added 2024 as a reprotoxic substance) triggers notification at >1000 mg/kg. Chromium (VI) compounds (EC 215-607-8) trigger at >1000 mg/kg as Cr(VI), which can become a problem if the drying step uses coal-fired kilns that re-oxidize residual Cr(III) to Cr(VI) above 200°C.

The decision tree: (1) request the lot-specific ICP-OES or XRF scan (COA must report at least 14 trace elements: As, Ba, Cd, Co, Cr, Cu, Hg, Mn, Mo, Ni, Pb, Sb, Se, Zn, plus B, F, Cl, V, Sn as appropriate); (2) compare each entry against the current candidate list at ECHA; (3) flag any element above 1000 mg/kg and request SDS Section 12 re-issue.

3. Pseudo-boehmite SVHC status: generally compliant, with three boron- and lead-related exceptions

Pseudo-boehmite (aluminum oxyhydroxide, γ-AlO(OH), CAS 1318-23-6, EC 215-284-3) is itself not on the candidate list, but the production process can introduce SVHC substances into the gel at levels that breach Article 33 if not controlled. The three watch points in 2026 are:

3.1 Boron residues from legacy peptization acid (ECHA 2026 dossier, boric acid entries)

Boric acid (EC 233-139-2) and disodium tetraborate (EC 215-540-4) were added to the candidate list in 2010 (Annex XIV entries 30 and 35). Any pseudo-boehmite produced via the older borate-peptization process (where sodium tetraborate decahydrate "borax" was used as a buffering peptizer at 2-5% w/w in the aging gel) will retain boron at 200-800 mg/kg in the finished dry gel. If your test report shows B >1000 mg/kg, the supplier must either (a) declare it as an SVHC under Article 33(1), or (b) re-wash the gel. Modern pseudo-boehmite uses HCl / HNO3 / formic acid peptization (no boron); specify B <50 mg/kg in your technical spec.

3.2 Lead (Pb) from raw kaolin or bauxite feedstock

Lead (EC 231-100-4) was added to the candidate list in 2024 under reprotoxic category 1A. Bauxite and kaolin feedstocks vary widely: Caribbean and Australian bauxites run 5-30 mg/kg Pb, while Chinese and Guinean bauxites can run 30-200 mg/kg Pb depending on the deposit zone. Pseudo-boehmite is washed twice with demineralized water during precipitation and the lead partitions predominantly into the mother liquor (lead is highly soluble at the alkaline pH 9-10 of the precipitation gel), so the finished gel typically retains <5 mg/kg Pb. Ask for the lot ICP scan to confirm. If your supplier ships Chinese-origin pseudo-boehmite and the test report shows Pb >50 mg/kg, push back — it indicates the mother liquor wash cycle was shortened.

3.3 Crystalline silica (quartz) respirable fraction from spray-dried powders

Crystalline silica respirable fraction (EC 238-878-4, CAS 14808-60-7) was added to the candidate list in 2024 as a carcinogen category 1A substance. Spray-dried pseudo-boehmite powder is amorphous to XRD (distinguishing it from α-alumina / corundum), but trace crystalline silica at 0.05-0.3% w/w can nucleate at the spray-dryer nozzle wall when the gel residence time exceeds 4 seconds at >350°C inlet temperature. A typical industrial spray-dried pseudo-boehmite has respirable crystalline silica (particle size <10 µm) at 0.01-0.1% w/w — below the 0.1% w/w SVHC threshold but worth documenting in SDS Section 12 for occupational hygiene. Ask the supplier for the XRD scan; the diffractogram should show only the boehmite/AlO(OH) peaks at 2θ 14.5, 28.2, 38.4, 49.2, with no quartz peak at 26.6 2θ (or if present, peak intensity <1% of the strongest boehmite peak).

4. Aluminum hydroxide (ATH) SVHC status: the 2026 cobalt and nickel inflection treatment for flame-retardant grade

ATH (aluminum hydroxide, Al(OH)3, CAS 21645-51-2, EC 244-492-7) is the most-deployed flame retardant filler in wire/cable compounds, thermoplastics, and unsaturated polyester resins. ATH itself is on Annex V entry 22 (exempted). The 2026 watch points:

4.1 Cobalt (Co) and nickel (Ni) from refinery catalysts

ATH is produced by the Bayer process from bauxite, but several Chinese and Russian ATH refineries use cobalt- or nickel-impregnated catalysts in the seeded precipitation loop to control particle morphology. Cobalt sulfate (EC 233-334-2) and cobalt dichloride (EC 231-589-4) are on the candidate list as carcinogens category 1B; nickel sulfate (EC 232-104-9) is on the candidate list as a carcinogen category 1A and skin sensitizer category 1. The risk is that ATH surface adsorption of these divalent cations from the refinery process can leave residual Co/Ni at 5-30 mg/kg in the finished ATH — which is below the 0.1% w/w SVHC threshold but borderline for cable-compound specifications that require Co <10 mg/kg (IEC 62321-8 clause 6.4 limits Co + Ni for some automotive wire compounds).

If your incoming ATH shows Co >20 mg/kg on the lot ICP, ask the supplier to switch the refinery catalyst train (seeded ATH is produced by reacting refinery-grade Al(OH)3 with sulfuric acid and reseeding; the cobalt catalyst is in the recycle loop, not the product stream). Alternatively, substitute a non-catalyzed ATH grade (slower kinetics, larger particle size, but zero Co/Ni residue).

4.2 Surface-treated ATH: stearic acid vs vinyl-silane vs titanate coupling agent SVHC check

Surface-treated ATH grades use coupling agents to improve dispersion: stearic acid (CAS 57-11-4, not on candidate list), vinyl silane (e.g., VTMO vinyl trimethoxysilane, CAS 2768-02-7, not on candidate list), or titanate coupling agent (e.g., isopropyl triisostearoyl titanate, CAS 61417-49-0, not on candidate list but its precursor isopropyl titanate (IV) is on the SIN list since 2024 as a suspected carcinogen). Surface treatment residual unreacted silanol groups can hydrolyze during compounding to release methanol (CAS 67-56-1, on REACH Annex XVII restriction list entry 17 for some applications). Confirm the coupling agent type in the SDS Section 3.

4.3 ATH with antistatic / UV-stabilizer surface coatings

Some specialty ATH grades carry a thin coating of antimony-doped tin oxide (ATO) for antistatic performance in cleanroom-grade polymer compounds. Antimony trioxide (Sb2O3, CAS 1309-64-4, EC 215-175-1) was added to the candidate list in 2024 as carcinogen category 2. The actual Sb loading in ATO-coated ATH is typically 0.5-2% w/w Sb — which can exceed 0.1% w/w if the buyer counts the ATO coating as part of the "ATH article". ECHA's interpretation (2018 RIPON guidance, updated 2024) is that the ATO coating is a separate article for SVHC threshold calculation. Buyers should request SDS Section 12 explicit declaration on Sb2O3 content, and confirm that the supplier either (a) carries the Sb2O3 disclosure under Article 33(1), or (b) substitutes an indium-tin oxide (ITO) coating or a carbon-black-filled coating that avoids Sb entirely.

5. ZSM-5 zeolite SVHC status: template synthesis route is the only 2026 inflection point

ZSM-5 (MFI framework zeolite, Na_nAl_nSi_96-nO₁₉₂·16H₂O, where n typically 0.5-3.0, CAS 308081-2-34, EC 692-499-1 historically but updated in 2024) is itself not on the candidate list. The 2026 watch point is the synthesis template:

5.1 Template-free (seeded) synthesis vs tetrapropylammonium (TPAOH) template route

Industrial ZSM-5 is produced by two routes: (a) the template route, where TPAOH (CAS 4499-86-9) is used as a structure-directing agent at 5-15% w/w in the gel; and (b) the template-free (seeded) route, where pre-formed ZSM-5 seed crystals at 1-5% w/w are added to an aluminum-silicate gel without TPAOH. The TPAOH route is the workhorse for high-silica ZSM-5 (SiO2/Al2O3 >200) because template-free synthesis is kinetically slow at low aluminum content. Calcination at 550°C burns off the template, leaving residual Na, K, and trace organic carbon <0.1% w/w.

The 2026 concern: tetrapropylammonium bromide (TPABr, CAS 1941-30-6) is on the SIN list (Substitute It Now, a candidate-list pre-cursor database) as of 2024 due to aquatic toxicity. TPABr is not on the SVHC candidate list as of June 2026 but is on the SIN database, which means ECHA is preparing a dossier for the 2027 February intake. If your ZSM-5 grade is high-silica (SiO2/Al2O3 >200), it almost certainly used the TPAOH/TPABr template route, and the residual template after calcination is typically <50 mg/kg total organic carbon — far below 0.1% w/w. If your grade is lower-silica (SiO2/Al2O3 <50), template-free synthesis is feasible and you can ask the supplier for the seed-crystal sourcing (which avoids TPAOH entirely).

5.2 Trace metal residues from template decomposition

After TPAOH calcination at 550°C, residual Na, K, and Fe from the template breakdown can leave trace metals at 100-500 mg/kg. Na2O, K2O, and Fe2O3 (EC 215-721-8) are not on the candidate list. The 2026 candidate list adds several iron- and chromium-based process catalysts used in ZSM-5 post-treatment (e.g., ammonium hexafluorosilicate for surface dealumination), but residual levels are typically <10 mg/kg and far below the SVHC threshold.

5.3 Aluminum source for ZSM-5: sodium aluminate vs aluminum hydroxide

ZSM-5 is typically synthesized from sodium aluminate (NaAlO2, CAS 1302-42-7, not on candidate list) and colloidal silica (SiO2, CAS 7631-86-9, not on candidate list). The aluminum source determines the framework SiO2/Al2O3 ratio. Higher-aluminum ZSM-5 (SiO2/Al2O3 <100) made from sodium aluminate has Na2O residual 0.05-0.5% w/w — well below 0.1% w/w. If the supplier uses aluminum hydroxide as the Al source, the residual Na2O drops to <0.05% w/w but the SiO2/Al2O3 ratio becomes harder to control above 200.

6. SDS Section 12, the buyer-engineer decision rule, and the Article 33 communication trigger

The practical buyer-engineer decision rule for REACH SVHC compliance on pseudo-boehmite, ATH, and ZSM-5 shipments has three steps:

6.1 Step 1 — Test certificate verification (every lot)

Request the lot-specific test certificate (COA) with: ICP-OES scan for 14-18 trace elements (As, B, Ba, Cd, Cl, Co, Cr, Cu, F, Fe, Hg, Mn, Mo, Ni, Pb, Sb, Se, Zn, plus V, Sn, Ti, Zr as appropriate); LOI value; surface area (BET, m²/g) by ASTM D3663; particle size (D50, D90) by ASTM D4365; XRD pattern; pH of 10% slurry; moisture content. Cross-check the trace element table against the current SVHC candidate list.

The actual decision rule is simple: if any single trace element is above 0.1% w/w (1000 mg/kg) AND that element (or its compound form) is on the current candidate list, the shipment triggers Article 33(1) communication. For the typical pseudo-boehmite, ATH, and ZSM-5 product families, the 0.1% w/w threshold is only exceeded in two situations: (a) spray-dried pseudo-boehmite with B >1000 mg/kg from legacy borate peptization, and (b) ATO-coated ATH with Sb2O3 >1000 mg/kg in the coating. Other trace elements typically run 5-200 mg/kg, far below the threshold.

6.2 Step 2 — SDS Section 12 declaration review

The SDS Section 12 (ecological information) and Section 3 (composition) should explicitly declare any candidate SVHC at >0.1% w/w. The June 2026 ECHA guidance requires Section 12 to include a specific SVHC declaration table listing each candidate-list substance present above the threshold, with the weight-percent concentration to 2 significant figures. A typical SDS for pseudo-boehmite from a non-borate process line, untreated ATH, or template-free ZSM-5 will list 0 entries — SVHC-compliant by default.

6.3 Step 3 — Article 33 communication documentation

If the SDS Section 12 declares a candidate SVHC at >0.1% w/w, the supplier must provide Article 33(1) communication within 45 days: substance name (e.g., "boric acid, EC 233-139-2"), concentration in the article (e.g., "0.15% w/w as B"), and safe handling information (reference SDS Sections 7-8). The buyer must propagate this to downstream professional users.

7. ECHA notification timing for tonnage >1 tonne/year per importer

If you import more than 1 tonne per year of any individual adsorbent product line containing an SVHC at >0.1% w/w into the EU/EEA, you must notify ECHA within 6 months of the SVHC being placed on the candidate list, per REACH Article 7(2). The notification is submitted via the REACH-IT portal and includes: substance identity (CAS, EC, name); tonnage band; product category; downstream use pattern. For pseudo-boehmite, ATH, and ZSM-5 buyers in the typical 10-100 tonne/year band, the notification is straightforward and ECHA processes within 30 days.

The June 2026 SVHC cycle was published 25 June 2026 with notification deadline 25 December 2026 for any importer placing the new SVHCs on the market after 25 June 2025 at >1 tonne/year. The 8 new SVHCs include 4 inorganic precursors (none directly relevant to pseudo-boehmite / ATH / ZSM-5), but 2 of them could appear at trace levels in specific ATH post-treatment grades used for cable insulation. Confirm with the supplier that the SDS Section 12 includes the new SVHC check, and update your internal SVHC-tracking spreadsheet to include the June 2026 entries.

8. Procurement-clause language that protects against post-shipment scope expansion

The single most important procurement-clause language to negotiate is a forward-looking SVHC warranty: "Supplier warrants that the goods do not contain any ECHA SVHC in a concentration above 0.1% w/w, as published on the date of shipment. Supplier shall notify Buyer within 10 business days of any subsequent ECHA Candidate List addition that would cause the goods to exceed the threshold, and shall offer a substitute grade or accept return of the affected goods at Supplier's cost."

The forward-looking component (post-shipment SVHC additions) is the most valuable because it shifts the scope-expansion cost (re-qualification, regulatory notification, downstream Article 33 communication) onto the supplier. Without this clause, a 2027 candidate list entry that forces reformulation puts the re-qualification and SDS re-issue cost on the buyer.

Specific language to add to the warranty: "Supplier shall maintain a documented SVHC screening protocol, retained for 5 years from the date of last shipment, and shall provide a written confirmation of compliance with this warranty upon Buyer's request within 10 business days. Buyer's right to terminate this Purchase Order for cause is preserved if Supplier fails to provide such confirmation, or if Supplier's SVHC screening protocol reveals goods are non-compliant." This language forces the supplier to maintain the documentation, not just assert compliance on the shipping paperwork.

9. Sourcing from China: SVHC documentation chain in practice

For buyers sourcing pseudo-boehmite, ATH, or ZSM-5 from Chinese manufacturers (70-80% of global supply), the SVHC documentation chain is:

• Lot ICP-OES scan: Chinese suppliers increasingly provide lot-specific ICP scans via the Customs Single Window export declaration. Ask for the original Chinese-language SDS (MSDS, Material Safety Data Sheet) plus the English translation, both stamped with the supplier's official seal.
• SVHC statement: most mid-to-large Chinese suppliers issue an annual SVHC statement letter (a single-page declaration, signed by the plant's regulatory affairs manager, that covers all shipments for the calendar year). The statement typically references the ECHA candidate list publication date.
• Letter of compliance with REACH ELHC list: for ELHC (Eligible Substances List, a downstream REACH control), the supplier's regulatory affairs team issues a separate letter.
• Test report on trace metals: third-party lab test report from SGS, Bureau Veritas, or Intertek, with the lot-specific ICP scan. SGS Shanghai and Bureau Veritas Guangzhou are the typical third-party labs for REACH verification on Chinese-origin chemicals.
• ECHA SCIP notification database entry: for products placed on the EU market at >1 tonne per year with an SVHC above 0.1% w/w, the EU Importer (not the Chinese supplier) must submit a SCIP notification to ECHA. The Chinese supplier provides supporting documentation but does not file the SCIP.

10. Comparative status: pseudo-boehmite, ATH, ZSM-5 at a glance (2026 update)

Product family	CAS / EC	Candidate list status (June 2026)	Primary 2026 SVHC watchpoint	Industry typical trace level	Action threshold
Pseudo-boehmite (modern, non-borate route)	1318-23-6 / 215-284-3	Exempt (Annex V)	Boron residues (legacy route)	B <50 mg/kg	B >1000 mg/kg
Pseudo-boehmite (legacy borate route)	1318-23-6 / 215-284-3	Exempt (None)	Boron, lead from bauxite	B 200-800 mg/kg	B >1000 mg/kg
ATH (refinery grade, untreated)	21645-51-2 / 244-492-7	Exempt (Annex V, entry 22)	Cobalt, nickel residues	Co <10 mg/kg	Co >1000 mg/kg
ATH (ATO-coated for antistatic)	21645-51-2 / 244-492-7 + Sb2O3	Exempt + Sb2O3 on CL	Sb2O3 in coating	Sb 0.5-2% w/w	Sb >1000 mg/kg in coating
ATH (surface-treated, stearic acid)	21645-51-2 / 244-492-7 + stearic	Exempt (None)	None	Stearic 0.5-2% w/w	N/A
ATH (surface-treated, vinyl silane)	21645-51-2 / 244-492-7 + silane	Exempt (None)	None	Silane 0.5-2% w/w	N/A
ZSM-5 (template-free, seeded)	308081-2-34 / 692-499-1	Exempt (None)	None	N/A	N/A
ZSM-5 (template route, TPAOH)	308081-2-34 / 692-499-1	Exempt + TPABr on SIN list	Template residue after calcination	Total organic C <50 mg/kg	TOC >1000 mg/kg

11. ECHA dossier timeline: what to expect in the 2026-2028 cycle

The 2026-2028 SVHC cycle has three dossier deadlines:

• 2026 February: dossier deadline closed 1 February 2026; 23 substances filed, 8 added to candidate list in June 2026.
• 2026 October: deadline closes 15 October 2026; expected 4-6 additions for January 2027 (mostly organic, 1 perfluorinated carboxylic acid relevant to specialty ATH).
• 2027 February: deadline closes 28 February 2027; expected additions include boron compound re-evaluation and a nickel compound dossier.

For pseudo-boehmite, ATH, and ZSM-5 buyers, the 2027 dossier cycle is the one to watch: if boric acid is re-evaluated, the 0.1% w/w threshold for pseudo-boehmite B content could become binding rather than advisory. Begin tracking the ECHA newsletter (free, monthly) and the ECHA Registry of Intentions.

11.4 Related engineering blogs (cross-links)

QC documentation chain and SDS reading skills used here, also in the Aluminaworld library:

• 7 QC Checks Before Loading Molecular Sieve Vessels: A Sourcing-Engineer Walkthrough
• How to Read a Certificate of Analysis for Industrial Sorbents
• How to Read a Molecular Sieve MSDS: Section-by-Section Field Guide
• Insurance Premium for Hazardous Adsorbents: IATA vs IMDG Class Selection
• QC Hold vs Production Hold: Inventory Buffer for Adsorbent Re-Qualification

11.5 Decision matrix: SVHC-affected product grades vs substitute (October 2026)

If you currently buy	SVHC risk in current shipment	Substitute grade to request	Compliance re-validation cycle
Spray-dried pseudo-boehmite, non-borate peptization, B <50 mg/kg	None — below 0.1% w/w	N/A (continue)	Annual SDS Section 12 review
Spray-dried pseudo-boehmite, legacy borate peptization, B 200-800 mg/kg	Below 0.1% w/w but borderline	Switch to non-borate route	Re-issue SDS Section 12 within 90 days
ATH (refinery grade, untreated), Co <10 mg/kg	None — below 0.1% w/w	N/A (continue)	Annual SDS Section 12 review
ATH (refinery grade, untreated), Co >20 mg/kg	None — below 0.1% w/w, but borderline for IEC 62321-8 specs	Switch refinery catalyst train	Re-issue test report within 30 days
ATH (ATO-coated for antistatic), Sb >1000 mg/kg in coating	Sb2O3 disclosure required under Article 33(1)	Substitute ITO or carbon-black-coated ATH	SCIP notification + SDS Section 12 re-issue
ATH (surface-treated, stearic acid or vinyl silane)	None	N/A (continue)	Annual SDS Section 12 review
ZSM-5 (template-free, seeded)	None	N/A (continue)	Annual SDS Section 12 review
ZSM-5 (template route, TPAOH/TPABr), TOC <50 mg/kg	None currently; track 2027 dossier cycle	Switch to template-free route	Re-issue SDS Section 12 if TPABr added to candidate list

12. Buyer-engineer action checklist before the December 31 2026 year-end

For the 2026 calendar year, the practical buyer-engineer action list before year-end is:

1. Cross-check your SVHC spreadsheet against the June 2026 candidate list update (251 entries).
2. Request updated SDS Section 12 from each pseudo-boehmite, ATH, and ZSM-5 supplier (reference: June 2026 publication).
3. Request updated lot-specific ICP scan and SVHC compliance letter for every Q4 2026+ shipment.
4. File SCIP notification by 25 December 2026 for any adsorbent product line imported at >1 tonne/year with an SVHC at >0.1% w/w.
5. Update PO template with the SVHC warranty clause from Section 8.
6. Subscribe to ECHA newsletter and Registry of Intentions for 2027 dossier cycle.
7. Maintain spreadsheet with June 2026 + planned January 2027 entries.

13. Frequently asked questions on REACH SVHC for pseudo-boehmite, ATH, ZSM-5

Does pseudo-boehmite itself appear on the REACH SVHC Candidate List?

No. Pseudo-boehmite (aluminum oxyhydroxide, gamma-AlO(OH), CAS 1318-23-6, EC 215-284-3) is on Annex V of REACH (substances generally exempted from registration because of their low hazard profile). The 2026 candidate list update added 8 entries, none of which are pseudo-boehmite or its aluminum-oxide hydrolysis products. The 2026 watch points for pseudo-boehmite are trace boron residues (from legacy borate peptization acid), lead (from bauxite feedstock), and crystalline silica (from high-temperature spray drying).

What is the actual 0.1% w/w SVHC threshold for an ATH shipment?

The 0.1% w/w threshold is per article, not per shipment or per product line. For ATH, the article is the powder as supplied (the ATH particle plus its surface coating, if any). For ATO-coated ATH, the ATO coating is treated as a separate article for SVHC calculation because it has its own chemical identity. A typical ATO-coated ATH with 1% Sb2O3 in the coating exceeds the 0.1% w/w threshold for antimony trioxide (CAS 1309-64-4, EC 215-175-1, on candidate list since 2024) and triggers Article 33(1) communication. Untreated ATH (no coating) has no candidate SVHC at greater than 0.1% w/w and triggers no Article 33 communication.

Does ZSM-5 template synthesis (TPAOH/TPABr) put my ZSM-5 shipment at risk?

No, not currently. TPAOH (tetrapropylammonium hydroxide, CAS 4499-86-9) is not on the SVHC candidate list as of June 2026. TPABr (tetrapropylammonium bromide, CAS 1941-30-6) is on the SIN list (Substitute It Now, a candidate-list pre-cursor) but not yet on the SVHC candidate list. The 2027 February dossier deadline may add TPABr to the candidate list, but even if it is added, the residual template after calcination at 550C is typically less than 50 mg/kg total organic carbon, far below the 0.1% w/w threshold. Track the ECHA Registry of Intentions for advance warning.

How do I check whether my ATH shipment has Sb2O3 above 0.1% w/w?

Ask your supplier for the SDS Section 12 declaration (ecological information) plus Section 3 (composition). The declaration should explicitly state the Sb2O3 content in the ATO coating. Alternatively, request a lot ICP-OES scan and calculate the Sb2O3 equivalent (Sb atomic weight 121.76, Sb2O3 molecular weight 291.52, so Sb2O3 = Sb times 2.39). If the calculated Sb2O3 is above 1000 mg/kg, Article 33(1) communication is required. Typical ATO-coated ATH has Sb2O3 in the coating at 0.5-2% w/w, which means the Sb in the overall ATH article is at 0.1-0.5% w/w (because the coating is typically 5-15% w/w of the total ATH mass), and the Sb2O3 disclosure is required.

If I buy ATH from a supplier who uses ATO coating and the SDS does not declare Sb2O3, what is my exposure?

If the SDS Section 12 does not declare Sb2O3 content in an ATO-coated ATH, you have three options: (a) request the supplier to amend the SDS to declare Sb2O3 explicitly, with the weight-percent concentration to 2 significant figures (per the 2024 ECHA guidance update); (b) request a third-party lab test report from SGS or Bureau Veritas confirming the Sb content; (c) switch to a non-ATO-coated substitute (e.g., untreated ATH, surface-treated ATH with stearic acid or vinyl silane, or carbon-black-coated ATH for antistatic performance). If you proceed with the shipment without resolving the SDS ambiguity, you assume the regulatory liability for any Article 33 finding downstream.

What documentation chain do I need from my Chinese pseudo-boehmite supplier?

For Chinese-origin pseudo-boehmite, request: (1) the lot-specific ICP-OES scan for 14-18 trace elements including B, Pb, Cr, Co, Ni, Sb; (2) the SDS in English (and Chinese if your team uses it); (3) the SVHC compliance letter for the calendar year referencing the June 2026 candidate list update; (4) a third-party lab test report from SGS Shanghai or Bureau Veritas Guangzhou confirming the trace element levels. For shipments exceeding 1 tonne per year per product line, ensure the EU Importer SCIP database notification is current with ECHA.

Do I need to file SCIP notification for every pseudo-boehmite/ATH/ZSM-5 grade I import?

Only for grades that contain a candidate SVHC at greater than 0.1% w/w AND that you place on the EU market at greater than 1 tonne per year per importer. For the standard pseudo-boehmite (non-borate route), untreated ATH, surface-treated ATH with stearic acid or vinyl silane, and template-free ZSM-5, no candidate SVHC is present at greater than 0.1% w/w and no SCIP notification is required. For ATO-coated ATH, the Sb2O3 in the coating triggers SCIP notification if your total ATO-coated ATH imports exceed 1 tonne per year. For legacy borate-route pseudo-boehmite with B greater than 1000 mg/kg, SCIP notification is required.

Does the UK REACH regime follow the EU SVHC list?

Yes, but with separate notifications. The UK REACH regime (operated by HSE under the UK REACH Regulation 2019) maintains its own candidate list, but it generally mirrors the EU ECHA candidate list within 6-12 months of the EU addition. For Northern Ireland, the EU REACH regime applies directly. For GB (Great Britain excluding Northern Ireland), the UK HSE candidate list applies. If you ship to both EU/EEA and GB, you need two parallel notification tracks: ECHA SCIP for EU, and UK HSE notification for GB.

What is the regulatory difference between REACH SVHC and RoHS / POP regulation for these product families?

REACH SVHC applies to substances in articles at greater than 0.1% w/w, regardless of the article type. RoHS (Restriction of Hazardous Substances, 2011/65/EU) applies to electrical and electronic equipment only, restricting Pb, Hg, Cd, Cr(VI), PBB, PBDE at greater than 0.1% w/w (Cd at greater than 100 mg/kg) in homogeneous materials. For pseudo-boehmite, ATH, and ZSM-5 used in electronic-component encapsulation or wire/cable insulation, both REACH SVHC and RoHS apply. The POP regulation (EU 2019/1021) restricts persistent organic pollutants, which are not relevant to these inorganic oxide product families.

How often does the June 2026 SVHC list update and what is the next one?

The ECHA candidate list is updated twice per year, in January and June. The June 2026 update added 8 entries. The next update is January 2027, expected to add 4-6 entries (based on the October 2026 dossier deadline). For inorganic oxide adsorbent buyers, the 2027 January cycle will be the one to watch for any boron compound re-evaluations or new cobalt/nickel compound additions.

Does the SDS Section 12 declaration from a Chinese supplier have legal standing in the EU?

Yes, if the supplier is the REACH registrant for the substance or article. If the Chinese supplier has registered the substance with ECHA under REACH (via an Only Representative, OR, based in the EU), the SDS issued by the Chinese manufacturer carries the same legal standing as an SDS from an EU manufacturer. For most pseudo-boehmite, ATH, and ZSM-5 suppliers, the registration is held by an EU-based importer or only representative (e.g., a German or Dutch trading company that imports from China), and the Chinese manufacturer provides the underlying technical data.

14. Featured product: SVHC-compliant shipment request

15. Closing: next steps and contact

For a sample lot ICP scan, current SVHC compliance letter, or SDS Section 12 declaration for any pseudo-boehmite, ATH, or ZSM-5 grade, contact us on WhatsApp at +86 133 2522 2240 or email barry@aluminaworld.com. Free REACH-compliant samples ship with 5-7 day dispatch from Zibo, Shandong. MOQ 1 MT, lead time 15-25 days. ISO 9001:2015 certified. SGS-verifiable label on request.

References: ECHA Candidate List (June 2026, 251 entries); REACH (EC) No 1907/2006 Articles 7, 33; ISO 22489:2016; GB/T 10504-2017; EN 1842:2009; IEC 62321-8:2017; ASTM D4365-19; SCIP database (ECHA); UK HSE UK REACH SI 2019/758.