The Candidate List and "251+4": Why the Number Keeps Growing

The direct answer

The SVHC Candidate List is a living document: member states propose substances, ECHA evaluates them, and the list grows in batches - reaching 251 substances as of November 5, 2025, with more always in the pipeline. The "251+4" in our report means the 251 listed substances plus 4 "assessing SVHC" substances that member states have submitted to ECHA but that are not yet on the list. For buyers, the number on the report is only meaningful with its date - last year's 240-substance report is already out of date this year.

How a substance becomes an SVHC

The path from chemical to Candidate List has defined steps:

1. Identification - a member state or ECHA proposes a substance as meeting the criteria of Article 57 (carcinogenic, mutagenic, toxic to reproduction, PBT, vPvB, or equivalent concern).
2. Public consultation - interested parties can comment, and the proposal goes through the scientific committees.
3. Decision - ECHA adds the substance to the Candidate List for authorisation.
4. Life after listing - listed substances trigger the 0.1% communication and notification duties, and may move toward the Authorisation List (Annex XIV) with use-by dates.

Each of these steps takes time, which is why the list grows in batches rather than by one substance at a time.

The growth pattern

The Candidate List started small and grew steadily:

The exact number always depends on the date. This is why a professionally written report states the list version - ours says "published on or before Nov 05, 2025" - so the reader knows exactly what was tested.

What "251+4" really covers

The "+4" is the part most buyers misunderstand. It refers to 4 assessing SVHC substances - substances submitted by EU member states to ECHA and under assessment, meaning they are the next candidates for the list. They are not yet listed, so they carry no legal communication duty yet - but screening them now is a head start. When those substances are formally added to the Candidate List, a report that already screened them remains meaningful instead of starting from zero.

Factory data: Our decision to test 251+4 was deliberate. The 4 assessing substances are the list of tomorrow, and a buyer who ships to the EU in six months will be asked about them. Screening them today means our Model 8404 documentation ages better than a report that stops at the official list.

What buyers should check about the number

• The list date - a report should name the version it tested (ours: Nov 5, 2025, 251 substances).
• The "+4" or equivalent pipeline scope - evidence that the factory looked beyond the current list.
• The substance detail - the report should include CAS and EC numbers, not just a count.
• The metal/non-metal split - the full list for non-metal, the applicable subset for metal.
• The report date vs the list date - the report must post-date the list version it claims to cover.

FAQ

How many substances are on the SVHC Candidate List in 2026?

The list grows in batches; as of our report's scope (November 5, 2025) it stood at 251 substances. The current number is always higher or equal - check the ECHA website for the latest update.

What are the "4 assessing SVHC" substances?

Four substances submitted by EU member states to ECHA and still under assessment - not yet on the Candidate List, but in the pipeline toward it. Our report screened them as part of the 251+4 scope.

Why does the number of SVHCs keep changing?

Because the list is updated in batches as member states propose substances and ECHA completes its evaluations. Compliance documents must track the version, not a fixed number.

Does a report from last year cover this year's list?

Only for the substances tested. Any substances added to the list after the report's scope date are not covered - which is why the list date on the report is essential.

How do I know which SVHCs apply to my product?

The report's component split tells you: non-metal materials screen the full list, metal components screen the applicable subset (73 in our report). The substance list with CAS numbers lets you compare against your own materials.

Where can I check the current Candidate List?

The ECHA website publishes the Candidate List with all updates, including the next batch of assessing substances. It is public, free, and the same source the labs use.

About this report

The list analysis in this article comes from report No. S260120016001-1 for our Model 8404 - 251 SVHCs (Candidate List, Nov 5, 2025) plus 4 assessing substances, all below 0.1%, with CAS and EC numbers on every line of the substance list. We share the full chemical list pages with buyers so they can verify scope substance by substance. Ask for them at clkbusiness@clkluggage.com or WhatsApp +86-18879628221.