What is an SVHC in the context of brass?

SVHC stands for Substance of Very High Concern — substances on ECHA's Candidate List that may eventually be subject to authorisation under REACH. As of January 2025 there are 240 SVHCs. Lead metal is on the SVHC Candidate List (listed as toxic for reproduction under Article 57(c) of REACH). CW617N brass contains approximately 2% lead by weight — well above the 0.1% Article 33 threshold. This means suppliers of CW617N into the EU must be prepared to provide Article 33 communication on request.

Is lead in brass an SVHC?

Yes. Lead metal (EC No 231-100-4) is listed on the ECHA SVHC Candidate List as a substance toxic for reproduction (Article 57(c) of REACH). Standard leaded brass (CW617N) contains approximately 1.6–2.5% lead — well above the 0.1% Article 33 notification threshold. Suppliers of CW617N brass into the EU must be able to respond to Article 33 inquiries by disclosing the presence of lead and providing information on safe use. Brassland proactively communicates lead content in all compliance documentation.

What is the SCIP database and does it apply to brass?

The SCIP database (Substances of Concern In articles, as such or in complex objects — Products) is an ECHA database established under the Waste Framework Directive (2008/98/EC, Article 9(1)(i)). From 5 January 2021, suppliers of articles containing SVHCs above 0.1% w/w that are placed on the EU market must submit information to the SCIP database. This applies to articles containing SVHCs — which includes brass fittings containing lead (an SVHC). EU distributors and importers of brass fittings with >0.1% lead must therefore submit SCIP notifications.

Does REACH registration apply to brass fitting manufacturers?

No. REACH registration applies to manufacturers or importers of chemical substances, not to manufacturers of articles. Brass fittings are articles — solid objects with a defined shape or design whose function is determined more by their shape than by their chemical composition. The brass manufacturer's alloy rod or wire suppliers may have registration obligations for the substances in those alloys, but a fitting manufacturer that machines articles from pre-registered alloy feedstock has no separate REACH registration duty.

How often does ECHA update the SVHC Candidate List?

ECHA typically updates the Candidate List twice per year — in January and June/July. As of January 2025, the list contains 240 substances. Brassland monitors every update and communicates to affected customers within 45 days of any change that affects the compliance status of supplied products, consistent with Article 33 obligations.

REACH Compliance for Brass & Copper Fittings: Complete 2025 Guide

Q: Does REACH apply to brass fittings?

Yes, but in a limited way. Brass fittings are classified as 'articles' under REACH (not substances or mixtures), which means manufacturers are not subject to REACH registration obligations. The main obligation is Article 33: if any SVHC from the Candidate List is present above 0.1% w/w in an article, the supplier must inform customers on request and proactively for B2B supply chains within 45 days of a new SVHC listing. Standard brass alloys (CW617N, CW602N) contain lead, which is on the SVHC list — so Article 33 obligations apply to leaded brass supplied into the EU.

Q: What is Article 33 of REACH?

Article 33 of REACH Regulation EC 1907/2006 requires that any supplier of an article containing a Substance of Very High Concern (SVHC) above 0.1% w/w must: (1) provide sufficient information to allow safe use of the article to their business customer, and (2) upon request from a consumer, provide that information within 45 days. The information must include at minimum the name of the SVHC substance. This obligation flows down the supply chain.

REACH is the most complex chemicals regulation on earth — and most brass fitting buyers receive a one-line declaration that tells them nothing. This guide explains exactly how REACH applies to brass fittings, what your supplier is legally obligated to tell you, what you can demand, and what the SCIP database means for your supply chain.

What REACH Is — and What It Is Not
Articles vs Substances: Where Brass Sits
The Three Pillars of REACH
What is an SVHC?
The Candidate List — 240 Substances
Lead in Brass: Full Legal Analysis under Article 33
Article 33 Obligations in Practice
The SCIP Database — New Obligation from 2021
Articles 57 & 59 — Authorisation Requirements
UK REACH Post-Brexit
REACH Status by Alloy
What to Demand from Your Supplier
Brassland's REACH Position
Frequently Asked Questions

What REACH Is — and What It Is Not

REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemicals. It is Regulation (EC) No 1907/2006 of the European Parliament and of the Council, adopted in December 2006 and administered by the European Chemicals Agency (ECHA). It entered into force in June 2007 and has been progressively implemented since.

REACH is often confused with RoHS, but they serve fundamentally different purposes. RoHS is a product restriction directive — it restricts specific substances in specific product categories (EEE). REACH is a chemicals management framework — it governs the registration, evaluation and authorisation of chemical substances across the EU market, with obligations flowing from substance manufacturers through the supply chain to downstream users and article producers.

For a brass fitting manufacturer, REACH obligations are primarily about communication and supply chain transparency — not about prohibiting the use of specific metals. The key question is not "can I use this alloy?" but rather "what do I have to tell my customer about what's in it?"

Articles vs Substances: Where Brass Sits

REACH draws a fundamental distinction between three categories of materials:

Category	Definition	Examples	REACH Registration Required?
Substance	A chemical element and its compounds in the natural state or obtained by a manufacturing process	Lead metal, zinc oxide, copper sulphate	Yes — if manufactured/imported in EU at ≥1 tonne/year
Mixture	A mixture or solution of two or more substances	Lubricants, cutting fluids, flux pastes	Component substances must be registered
Article	An object given a special shape, surface or design during production, which determines its function to a greater degree than its chemical composition	Brass fittings, copper pipes, aluminium extrusions	No registration obligation

Brass fittings are articles. A compression elbow, a valve body, a push-fit connector — these objects have their function determined by their shape and design (the thread form, the compression seat, the valve seat geometry) rather than by their chemical composition alone. This classification removes the REACH registration burden from fitting manufacturers.

However, the alloy rod or billet feedstock from which fittings are machined — when supplied as a chemical substance by a smelter or alloy producer — may require REACH registration. The upstream suppliers of brass alloy (EN 12164 CW617N rod) must ensure their substances are properly registered under REACH. Brassland sources from REACH-compliant alloy suppliers.

The Three Pillars of REACH

Pillar 1

Registration

Substance manufacturers/importers (≥1t/y) must register with ECHA. Applies to alloy suppliers — not to fitting manufacturers.

Pillar 2

Evaluation

ECHA evaluates dossiers and may request further information. Ongoing process for substances of concern.

Pillar 3

Authorisation & Restriction

SVHCs may be restricted (Annex XVII) or require authorisation (Annex XIV). Applies to substances, not articles (with exceptions).

Where Fitting Manufacturers' Obligations Lie

For article producers (fitting manufacturers), REACH obligations are concentrated in three areas:

Article 7(1): Registration of substances in articles if the substance is intended to be released under normal or foreseeable conditions of use AND the substance is not already registered for that use. (Rarely applies to brass fittings — lead in brass is not intended to be released.)
Article 7(2) / Article 33: Notification and communication duties for SVHCs present above 0.1% w/w in articles. This is the primary obligation for brass suppliers.
SCIP Database (Waste FWD Art. 9(1)(i)): Obligation to submit SVHC-in-article information to the ECHA SCIP database for articles placed on the EU market from January 2021.

What Is an SVHC?

An SVHC — Substance of Very High Concern — is a chemical substance identified by ECHA as having particularly hazardous properties. REACH defines SVHCs in Article 57 as substances that are:

CMR substances (Art. 57a/b/c): Carcinogenic, Mutagenic, or Toxic for Reproduction (categories 1A or 1B)
PBT substances (Art. 57d): Persistent, Bioaccumulative and Toxic
vPvB substances (Art. 57e): Very Persistent and Very Bioaccumulative
Equivalent concern (Art. 57f): Substances with equivalent concern to the above, e.g. endocrine disruptors

SVHCs first appear on the SVHC Candidate List when ECHA proposes them (following a "substance evaluation" by a member state or ECHA). They may subsequently be moved to the Authorisation List (Annex XIV), at which point their use requires authorisation from ECHA. Being on the Candidate List does not itself restrict the substance — it triggers supply chain communication obligations (Article 33) and SCIP database notification requirements.

The Candidate List — 240 Substances (as of January 2025)

The SVHC Candidate List is maintained and updated by ECHA at echa.europa.eu/candidate-list-table. It is updated approximately twice per year — in January and June/July. As of January 2025, it contains 240 substances.

Of these 240 SVHCs, the following are directly relevant to brass and copper alloy fittings:

⚠️ Lead (EC 231-100-4) — Toxic for Reproduction. In standard leaded brass at 1.6–3.5%
⚠️ Lead compounds (various EC nos.) — CMR. Relevant if lead-containing compounds used in coatings
⚠️ Arsenic (EC 231-148-6) — CMR Cat.1A carcinogen. May occur in trace amounts in some copper alloys
⚠️ Nickel (EC 231-111-4) — CMR. Relevant for nickel-plated brass fittings
⚠️ Cobalt (EC 231-158-0) — CMR. Not in standard brass alloys
⚠️ DEHP phthalate (EC 204-211-0) — Toxic for Reproduction. Relevant to polymer gaskets/seals in fitting assemblies

For solid brass alloy (the metal fitting body), the substance of principal concern is lead metal — and only in CW617N and CW614N grades. CW602N (DZR) contains ~0.2–0.3% lead, which still exceeds the 0.1% Article 33 threshold. Pure copper alloys (C101, C102) do not contain SVHC substances above the threshold under current assessments.

ℹ SVHC assessment is at article level, not substance level

The 0.1% threshold applies to the article as supplied (the fitting), not to the alloy composition in isolation. A CW617N fitting containing 2% lead by alloy weight: the entire fitting is the "article". If the fitting weighs 100g, it contains ~2g of lead — 2% of the article weight. This exceeds 0.1% w/w, triggering Article 33 obligations. For a complex assembly (fitting + seal + nut), the assessment may be at the complex object level or the component level — ECHA's guidance on "complex objects" provides the framework.

Lead in Brass: Full Legal Analysis Under Article 33

This is the question that generates the most confusion in brass supply chains. Here is a structured legal analysis:

Question	Answer	Source / Basis
Is lead metal on the SVHC Candidate List?	Yes	ECHA Candidate List — Lead, EC 231-100-4, listed as Repr. Cat 1A/1B
Does CW617N contain lead above 0.1%?	Yes — ~2%	EN 12164 alloy specification: Pb 1.6–2.5%
Does this trigger Article 33 obligations?	Yes	REACH Art. 33(1): SVHC >0.1% in article → communication obligation
Must Brassland register lead under REACH?	No	Registration applies to substance manufacturers/importers. Brassland is an article producer.
Must Brassland notify ECHA under Art. 7(2)?	If tonnage threshold met	REACH Art. 7(2): notification if SVHC-in-article >1 tonne/year total and >0.1% per article. Brassland notifies as required.
Must Brassland submit to SCIP database?	Yes — for EU market	Waste FWD Art. 9(1)(i): SCIP submission required for articles with SVHC >0.1% placed on EU market from Jan 2021
Does this mean the fitting is "non-compliant"?	No	REACH does not restrict lead in brass articles. Obligation is communication, not prohibition.
Does RoHS separately restrict lead in brass?	Only for EEE — via Exemption 6(c)	RoHS Directive 2011/65/EU, Annex III Exemption 6(c). See RoHS guide.

In plain language: lead in CW617N brass is lawful under REACH. REACH does not ban lead in brass fittings. What REACH requires is that if you supply a CW617N brass fitting to a business customer in the EU, you must be able to provide information about the lead content upon request. This is an Article 33 communication obligation, not a use restriction.

Article 33 Obligations in Practice

Article 33 of REACH contains two distinct obligations:

Article 33(1) — B2B communication

Any supplier of an article containing an SVHC in a concentration above 0.1% w/w shall provide the recipient of the article with sufficient information to allow safe use of the article, including, as a minimum, the name of the SVHC. This obligation applies without the customer having to ask — it should be part of standard supply documentation for articles containing SVHCs above threshold.

Article 33(2) — Consumer communication

Any supplier of an article containing an SVHC in a concentration above 0.1% w/w shall, following a request by a consumer, provide the consumer with sufficient information to allow safe use of the article, including, as a minimum, the name of the SVHC. This information must be provided free of charge within 45 days of the request.

What "sufficient information to allow safe use" means in practice

ECHA guidance specifies that this should include: the name of the SVHC (e.g. "Lead, CAS 7439-92-1"), any information that enables the customer to take appropriate risk management measures. For lead in brass fittings, this typically means: "This article contains lead (CAS 7439-92-1) at approximately [X]% by weight. Standard engineering precautions for lead-containing materials apply: wash hands after handling, do not machine or cut without appropriate dust control, keep away from children. Lead is not released under normal conditions of use of the fitting."

Supply Chain Flow of Article 33 Obligations

REACH is a supply chain regulation. The obligation does not end at the first sale — it flows down the chain:

Alloy rod supplier → Brassland: Alloy supplier must communicate SVHC content (lead) in the rod supplied to Brassland
Brassland → EU distributor/importer: Brassland must communicate lead presence in fittings to the EU customer
EU distributor → OEM/installer: Distributor must pass the SVHC information to their customer
Retailer → Consumer: Retailer must respond within 45 days to consumer SVHC enquiries

Failure to communicate SVHC information at any step in the chain breaks the legal chain of compliance. Many supply chains have this gap — manufacturers provide the information to their direct customer but the distributor never passes it on. ECHA has enforcement actions underway in several EU countries targeting this gap.

The SCIP Database — New Obligation from January 2021

The SCIP database (Substances of Concern In articles, as such or in complex objects — Products) was established by Article 9(1)(i) of the revised Waste Framework Directive (2008/98/EC). From 5 January 2021, companies placing articles on the EU market that contain SVHCs above 0.1% must submit information about those articles to the SCIP database.

Who must submit to SCIP?

The obligation applies to suppliers who place articles on the EU market. For brass fittings containing lead (an SVHC), this means:

EU-based distributors who import brass fittings from Brassland and place them on the EU market
EU manufacturers who incorporate Brassland fittings into finished products placed on the EU market
Non-EU manufacturers who directly supply articles to EU customers (they may need to nominate an EU representative)

What SCIP information is required?

The SCIP notification must include: article identifier (description, reference number), safe use information, and SVHC information (name, CAS number, concentration range). The data is stored in ECHA's SCIP database and made available to waste operators, enabling them to handle SVHC-containing products appropriately at end of life.

⚠ SCIP is the obligation of the EU market supplier, not the Indian exporter

Brassland is an Indian exporter — we do not place articles on the EU market directly. Our EU customers (distributors, OEMs) are the "suppliers" for SCIP purposes. However, we provide all the technical information our EU customers need to fulfil their SCIP obligations: SVHC substance name and CAS number, concentration range by alloy, and safe use information. Contact us for a SCIP data package.

Articles 57 & 59 — Could Lead in Brass Ever Be Restricted?

A natural follow-up question: could lead in brass be added to the REACH Authorisation List (Annex XIV), which would require authorisation for continued use?

Article 57 defines which substances can be SVHCs. Article 58 describes the process for adding SVHCs to the Authorisation List (Annex XIV). Article 59 describes the process for identifying SVHCs for the Candidate List. The pathway from Candidate List to Authorisation List is: Candidate List → Annex XIV inclusion → authorisation required for specific uses.

Lead metal is on the Candidate List. It is not currently on the Authorisation List (Annex XIV). Adding it would require a full ECHA recommendation and Commission decision, weighing the socioeconomic benefits against the risks and the availability of alternatives. Given the breadth of lead use in industrial applications and the ongoing availability of exemptions under RoHS Directive, the likelihood of lead in solid brass articles being restricted under REACH authorisation is considered low by industry analysts. However, monitoring the ECHA regulatory development pipeline is prudent for long-term planning.

Annex XVII Restrictions — a separate pathway

REACH Annex XVII contains substance restrictions that apply more broadly than Authorisation. Lead is already restricted in certain Annex XVII entries — notably Entry 63 (lead in articles for consumer use in concentrations above 0.05%, with exemptions for brass). The Entry 63 exemption for brass explicitly provides that it does not apply when the article is intended for children, or in specific consumer categories. For industrial and professional B2B brass fittings, Entry 63's brass exemption applies.

UK REACH Post-Brexit

Following Brexit, the UK established its own chemicals regulation: UK REACH (retained by the European Union (Withdrawal) Act 2018 and administered by the Health and Safety Executive (HSE) under the REACH Etc. (Amendment etc.) (EU Exit) Regulations 2019).

UK REACH closely mirrors EU REACH but operates as a separate legal framework. Key differences:

Substances must be separately registered under UK REACH (the UK maintains its own registration database)
UK has its own SVHC Candidate List — currently mirrors EU REACH list but may diverge over time
Article 33 communication obligations exist under UK REACH equivalent provisions
HSE (not ECHA) administers UK REACH

EU REACH compliance does not automatically confer UK REACH compliance. UK importers of brass fittings containing SVHCs (including leaded brass) need to satisfy UK REACH Article 33 equivalent obligations.

REACH Status by Alloy

Alloy	Pb content	Lead SVHC threshold triggered?	Article 33 obligation?	SCIP notification?
CW617N (free-machining)	1.6–2.5%	Yes — exceeds 0.1%	Yes	Yes (EU market suppliers)
CW614N (high-tensile)	2.5–3.5%	Yes — exceeds 0.1%	Yes	Yes (EU market suppliers)
CW602N (DZR low-lead)	0.2–0.3%	Yes — exceeds 0.1%	Yes	Yes (EU market suppliers)
CW724R (silicon brass)	<0.09%	No — below 0.1%	No (for lead)	No (for lead)
C101/C102 (copper)	<0.01%	No	No	No

What to Demand from Your Supplier

A REACH "compliance certificate" from a supplier is only as good as the information it contains. Here is a checklist of what a proper REACH statement for brass fittings should include:

Required element	What it should say	Red flag if absent
Article classification	Confirms product is an "article" under Art. 3(3) of EC 1907/2006	Supplier treats fitting as a substance
Registration status	States that upstream alloy suppliers hold REACH registrations for alloy substances	Supplier claims their own REACH registration
SVHC identification	Identifies lead (CAS 7439-92-1) as SVHC present above 0.1% in leaded alloys	Claims "no SVHCs present" for CW617N — false
Lead concentration	Gives Pb% range per alloy (e.g. CW617N: 1.6–2.5% Pb per EN 12164)	No quantification of lead content
Article 33 statement	Confirms Art. 33 communication obligation acknowledged and discharged	No reference to Article 33
SCIP support	States that data for SCIP notification is available on request	No mention of SCIP
Safe use information	Provides handling/safe use information for lead-containing articles	No safe use guidance
Monitoring commitment	States that ECHA Candidate List updates are monitored and customers notified within 45 days of relevant changes	No monitoring commitment
Signatory and date	Signed, dated, with name and title of responsible person	Unsigned or undated

Brassland's REACH Position

✅ Brassland REACH Compliance Summary

Classification: All Brassland brass, copper and aluminium fittings are articles under Article 3(3) of REACH Regulation EC 1907/2006. No REACH registration obligation applies to Brassland as article producer.
SVHCs: Lead (CAS 7439-92-1) is present above 0.1% w/w in CW617N, CW614N, and CW602N alloys. Brassland proactively communicates this in compliance documentation supplied to all EU and UK customers.
Article 33 compliance: Brassland issues REACH Article 33 compliance statements with every shipment to EU/UK customers. These statements identify all SVHC substances present above 0.1% and provide safe use information.
SCIP support: Brassland provides a SCIP data package to EU importers on request, including article description, SVHC name/CAS/concentration, and safe use information for SCIP database submission.
Candidate List monitoring: Brassland monitors every ECHA Candidate List update (approx. Jan and July each year) and issues updated compliance statements to customers within 45 days of any change affecting supplied products.
Upstream compliance: Brassland sources alloy feedstock from mills that maintain REACH registrations for their chemical substances. Registration documentation available on request.

Frequently Asked Questions

Does REACH apply to brass fittings? +

Yes, but primarily through Article 33 communication obligations. Brass fittings are "articles" under REACH — not subject to substance registration. The key obligation is Article 33: if an SVHC (like lead) is present above 0.1% w/w, the supplier must communicate this to customers. CW617N brass contains ~2% lead (an SVHC), so Article 33 obligations apply for EU/UK supply.

Is lead in brass a problem under REACH? +

Lead is on the SVHC Candidate List, but REACH does not restrict lead in brass articles. The obligation is communication, not prohibition. CW617N fittings containing ~2% lead can be lawfully supplied to EU customers provided the lead content is disclosed under Article 33. There is no REACH restriction on using or buying leaded brass fittings.

What is the SVHC Candidate List? +

The SVHC Candidate List is published by ECHA under REACH and contains Substances of Very High Concern — chemicals identified as CMR (carcinogenic, mutagenic, toxic for reproduction), PBT (persistent, bioaccumulative and toxic), or vPvB. As of January 2025, it contains 240 substances. Being on the Candidate List triggers Article 33 supply chain communication obligations and SCIP database notification requirements, but does not restrict the use of the substance in articles.

What is the SCIP database and who has to submit to it? +

SCIP (Substances of Concern In articles, as such or in complex objects — Products) is an ECHA database for articles containing SVHCs above 0.1% placed on the EU market. EU importers and distributors of brass fittings containing lead (above 0.1%) must submit article information to SCIP from January 2021. Non-EU exporters like Brassland are not directly obligated to submit, but we provide SCIP data packages to EU customers on request.

Does my supplier need to be REACH registered? +

Your fitting supplier does not need to be REACH "registered" — registration applies to chemical substance manufacturers and importers, not to article producers. What your supplier should do is: (a) source from REACH-compliant alloy suppliers, (b) issue proper Article 33 SVHC declarations, and (c) support your SCIP obligations. If a supplier claims they are "REACH registered" as a fitting manufacturer, this is either a misunderstanding or a misleading claim.

What is Article 33 of REACH and what does it require? +

Article 33 requires that any supplier of an article containing an SVHC above 0.1% w/w: (1) provides sufficient information to allow safe use to their business customer — proactively; and (2) responds to consumer requests within 45 days free of charge. The information must at minimum name the SVHC. For brass containing lead, this means communicating: the substance name (Lead), CAS number (7439-92-1), concentration range, and safe use information.

Does UK REACH still apply after Brexit? +

Yes. The UK has its own REACH regulation, administered by HSE. It mirrors EU REACH but is a separate legal framework with separate registration requirements. Article 33 equivalent obligations apply in the UK. EU REACH compliance does not automatically satisfy UK REACH. Brassland provides declarations covering both EU REACH and UK REACH for customers supplying both markets.

How often is the SVHC Candidate List updated? +

ECHA updates the Candidate List approximately twice per year — typically in January and June/July. Each update adds substances and may modify existing entries. Brassland monitors every update and will proactively notify affected customers within 45 days of any change that affects the compliance status of supplied products, consistent with our Article 33 obligations.

Is there a difference between REACH and RoHS? +

Yes — they are completely separate regulations with different scope and obligations. REACH (EC 1907/2006) is a chemicals management framework covering all products — it triggers communication and potentially authorisation obligations based on SVHC content. RoHS (Directive 2011/65/EU) restricts 10 specific substances in electrical and electronic equipment. A brass fitting can comply with both simultaneously. See our RoHS guide for full detail on RoHS obligations.

Primary Sources & Further Reading

This guide is maintained by Brassland and reviewed at each ECHA Candidate List update. Last updated: May 2026. This guide is informational and does not constitute legal advice. For legally binding compliance assessments, consult a qualified REACH specialist. ECHA Candidate List status should always be verified against the live ECHA website before making compliance decisions.