The 0.1% Rule: Thresholds, Articles and the Two EU Obligations

REACH compliance series. This article is the 0.1% rule — thresholds, articles and the two EU obligations. Start at the hub: What REACH Actually Is: The EU Regulation Explained.

A buyer emailed me a REACH report last month and asked one question: "Did we pass?" I asked a question back before answering: what threshold does the report test against? Because a "pass" against the wrong threshold tells you nothing.

So here's the direct answer first: 0.1% weight by weight is the REACH threshold for SVHCs in articles. Below it, there is no communication duty. At or above it, the supplier must provide information under Article 33 — and the importer may also have a notification duty under Article 7(2) if the total quantity exceeds one tonne per year.

Our Model 8404 report tests every component against exactly this threshold. Every result sits below 0.1%, most at not-detected. That's what makes the declaration possible.

What the 0.1% Threshold Applies To

The threshold applies per article — and for a product like a suitcase, the practical reading is per component or homogeneous material.

A zipper. A buckle. A strap. A shell panel. Each is assessed separately.

This matters more than it looks. A product where one tiny component exceeds 0.1% carries the communication duty even if the suitcase as a whole is almost clean. That's why component-level testing exists — and why "we tested the suitcase" is a weaker answer than "we tested each material."

The Two Obligations, Explained

Article 33: communication to recipients

If an article contains an SVHC above 0.1%, the supplier must give the recipient enough information for safe use — at minimum, the name of the substance. The duty runs all the way down the supply chain, from factory to importer to retailer.

Article 7(2): notification to ECHA

If the SVHC is present above 0.1% and the total quantity exceeds one tonne per producer or importer per year, the importer must notify ECHA. Note who acts: this is an importer-side obligation. The factory cannot file it for you.

Obligation	Trigger	Who acts
Article 33 communication	SVHC > 0.1% in an article	Supplier to recipient
Article 7(2) notification	SVHC > 0.1% AND > 1 tonne/year	EU importer or producer

What Our Report Demonstrates

The report's conclusion line is specific: "concentrations of SVHC (251 SVHC) are less than 0.1% (w/w) in the sample." On the non-metal sample, all 251 substances came back not-detected; on the metal sample, all 73 applicable substances came back not-detected.

Below 0.1% means the Article 33 and Article 7(2) triggers do not fire for the tested components. That's the evidence that keeps the paperwork quiet.

Factory data, straight: when we review a REACH report, the first number we look at is not the verdict — it's the threshold line. "Pass" against a different threshold tells you nothing. Our report states 0.1% (w/w) explicitly and tests each component against it, because that is the number the EU obligations actually use.

Why Component-Level Testing Is the Honest Scope

A suitcase is not one material. Testing "the suitcase" as a single sample can hide a hotspot in one component — or, just as misleading, dilute a clean result.

Component-level testing — non-metal and metal separately, as our report does — gives each material its own verdict. So when a supplier hands you a report, ask which materials were tested and how they were split. Not just whether the product "passed."

Frequently Asked Questions

What does 0.1% (w/w) mean in REACH?

0.1% weight by weight — the concentration of an SVHC in an article above which communication and notification duties are triggered. Our report tests every component against this threshold.

Does the 0.1% apply to the whole suitcase or each component?

Per article — and in practice, per component or homogeneous material. Each part is assessed separately, which is why component-level testing is the meaningful scope.

What happens if a component exceeds 0.1%?

The supplier must communicate the substance information to the recipient (Article 33), and if the total quantity exceeds one tonne per year, the importer must notify ECHA (Article 7(2)). It does not automatically ban the product, but it creates duties.

Is below 0.1% the same as "no SVHC"?

No. Below 0.1% means the concentration is under the threshold — often not-detected at the lab's reporting limit. The report documents that no duty-triggering concentration was found in the tested scope.

Who files the ECHA notification?

The EU importer or producer. A factory outside the EU cannot file it; the importer uses the factory's data to do so when the trigger applies.

How do I keep the 0.1% story true across batches?

A report proves one sample. Keep the material supply stable, require component declarations from suppliers, and re-test when materials, sources, or components change.

About the Author

Written by the CLK Manufacturing Team — 16+ years of custom luggage OEM/ODM experience from our factory in Ji'an, Jiangxi, China. Updated: 2026-08-15.