A plasticizer quote lands with a safety data sheet and a one-line claim of REACH compliance. Whether that claim is enough to sign the purchase order depends on which of three REACH lists the substance touches.
Those three are the Authorisation List (Annex XIV), the Restriction List (Annex XVII), and the SVHC Candidate List. Each carries a different obligation, and treating them as one “REACH banned list” produces false rejections of compliant material and false approvals of restricted material.
Verifying a supplier means running the substance against each list, demanding the documents that evidence its status, and knowing which paperwork gaps should stop the order before it ships.
How Annex XIV and Annex XVII Differ for Plasticizers
Annex XIV (Authorisation) bars a substance from EU use after a sunset date unless the operator holds a granted authorisation, regardless of concentration. Annex XVII (Restriction) caps a substance at a concentration threshold in defined applications. The same four ortho-phthalates — DEHP, BBP, DBP, and DIBP — sit on both lists, which is why buyers conflate them.
| REACH list | What a hit means | Trigger | Plasticizers named |
|---|---|---|---|
| Annex XIV (Authorisation) | No EU use after sunset without an authorisation | Any use | DEHP, BBP, DBP, DIBP (entries 4-7) |
| Annex XVII (Restriction) | Capped in defined applications | 0.1% by weight | Entry 51: DEHP, BBP, DBP, DIBP; Entry 52: DINP, DIDP, DNOP |
| SVHC Candidate List | Disclosure duty flows downstream | 0.1% by weight | 11 phthalates, incl. DEHP, DBP, BBP, DCHP |
The Annex XIV entries carry a trap that pre-2021 compliance files miss. A 2021 amendment added endocrine-disrupting properties to entries 4-7 and removed the old exemptions for medical devices, food-contact materials, and immediate packaging of medicinal products.
Material that a 2019 declaration cleared for a food-contact PVC application may now need an authorisation it never held. The original sunset dates for the four legacy phthalates passed in 2015, and applications for the newly covered uses closed in 2023. Any current EU use of these substances now turns on a granted authorisation.
Entry 51 tells a different story on the restriction side. It exempts a handful of applications — motor vehicles, aircraft, and laboratory measuring devices — so a phthalate that fails for a consumer article can still be lawful in an automotive part.
REACH governs the EU market only. A supplier shipping the same compound into other jurisdictions faces different phthalate rules by region, which the EU audit does not settle.
How to Screen the SVHC Candidate List
ECHA’s SVHC Candidate List held 253 substances as of its 4 February 2026 update, and eleven of them are phthalates. Screen your plasticizer’s CAS number against that current version on the ECHA site — not a copy cached at onboarding.
The list is revised roughly twice a year, so a declaration is only as trustworthy as the list version it names. The regulatory landscape is shifting toward broader hazard criteria, too: the February 2026 additions included n-hexane, the first substance listed on neurotoxicity rather than the classic carcinogenic, mutagenic, or reprotoxic grounds.
Once a listed SVHC exceeds 0.1% by weight in an article, Article 33 pushes an information duty downstream to every customer, with consumer requests answerable within 45 days. Screening once at onboarding and filing the result as permanent is the most common failure here — the list moves under you.
A non-phthalate plasticizer such as DOTP is not currently on the Authorisation List or in the entry 51 restriction group, so the audit shortens to Candidate List screening plus the standard documents. Keep the “not currently” caveat, and re-check it each cycle.
What Documentation Proves REACH Compliance
A supplier proves REACH status with a document set, not a one-line claim. Four items carry the evidence: a version-referenced declaration, a complete safety data sheet, the registration number, and batch test data.
- REACH/SVHC declaration — states SVHC status against a named Candidate List version and date, confirms Annex XVII compliance, and gives Annex XIV authorisation status.
- Safety data sheet, Section 15 — the regulatory section; blank or generic entries mean the SDS was never checked against this substance.
- Registration number — evidence the substance is registered for use above one tonne a year, which is market access, not list clearance.
- Test reports — phthalate-content or migration data that tie the declaration to the batch you are actually buying.
The most auditable line in that set is the Candidate List version. A declaration screened against “253 substances, 4 February 2026” can be checked against the record; one that names no version or date cannot be audited at all.
A full REACH audit is only the regulatory slice of qualifying a plasticizer manufacturer, layered on top of the usual quality and supply checks.
REACH Compliance Red Flags That Should Stop the PO
Stop the purchase order when the paperwork shows any of these gaps, each a sign the supplier cannot evidence list status:
- No named Candidate List version — a declaration screened against an unnamed list cannot be checked against the record at all.
- “REACH registered” as proof — registration is a market-access prerequisite above one tonne a year, the restricted phthalates included, and says nothing about Annex XIV or XVII status.
- “Phthalate-free” without a CAS number — the claim is marketing until a test backs it. Phthalate detection ranks among the more common lab-test failures, so verifying a phthalate-free claim before you sign is a separate lab step.
- A stale regulatory reference — a declaration citing a superseded Annex XVII or Candidate List version predates changes that may already have caught your substance. Compliance requirements now include the current list versions.
Next Steps
Before requesting a single document, run the plasticizer’s CAS number against Annex XIV, the entry 51 and 52 groups in Annex XVII, and the current Candidate List. That three-way check tells you which obligation you are actually buying into.
Then let the declaration’s named list version be the gate: no version, no date, no approval. It is the fastest way to separate an auditable supplier from one hoping you will not look closely. Tie a re-screen to each Candidate List update, roughly twice a year, and the audit becomes a standing control rather than a one-time hurdle.