Test reports, declarations, SDSs and material data: choosing REACH evidence

Choose evidence after identifying the duty：Four document types answer different questions

Material data and supplier declarations can create traceability from product to part and substance. A test report answers a defined sample-and-analyte question. An SDS communicates safety information for specified substances or mixtures. They should not be treated as interchangeable labels.

For articles, Article 33 communicates safe-use information to recipients and consumers; Article 7 concerns producer/importer registration or notification conditions; SCIP is a separate Waste Framework Directive submission. The evidence package must match the duty being assessed.

Bottom line first

• Material data creates composition and traceability links.
• A declaration states the supplier’s known information and commitment scope.
• A test report answers a sample-and-analyte question.
• An SDS supports safe-use communication for substances and mixtures.
• Article 33, Article 7 and SCIP do not replace one another.

Information needed before deciding

• Conclusion to be supported and applicable legal provision
• Whether the product is an article and is supplied on the EU market
• Supplier, importer, producer or distributor role
• Candidate List SVHC and concentration in each constituent article
• Total annual tonnage and intended-release information
• Whether the recipient is professional, distributor or consumer
• Material-data CAS/EC number, scope and revision
• Declaration product/lot, list version and limitations
• Test method, sample, analytes and detection/quantification limits
• SCIP submission identifier and safe-use information where applicable

Practical decision flow

Define the question

State whether the task is Article 33 communication, SVHC screening, Article 7 or SCIP.

Build the product tree

Link the finished product, constituent articles, parts, materials and documents.

Collect supply-chain data

Gather material declarations, supplier declarations, SDSs and change information.

Validate scope

Check that each document corresponds to the current product, list, material and market.

Use testing for gaps

Design sampling and analysis only for chemical questions reliable documentation cannot answer.

Deliver the applicable information

Communicate safe-use information, assess notification or submit SCIP data as applicable.

What different evidence can support

Evidence	What it can support	Important limitation
Material declaration/material data	Structured traceability between parts and substance information	Quality depends on source and version control
Supplier declaration	A supplier confirmation for a product and list scope	It may not reveal every material or analytical basis
Safety data sheet	Hazard, safe-use and supplier information for an applicable substance or mixture	Not every article communicates Article 33 information through an SDS
Test report	Analytical results for named analytes in an identified sample	It is not a guarantee for the whole product, list or future lots
SCIP submission record	That a specified submission and its information have been created	It does not replace Article 33 communication to recipients or consumers
Article 33 information package	Safe-use information and substance name communicated to a customer	It depends on reliable supply-chain or analytical data

Common mistakes

Mistake：Using a SCIP number instead of Article 33 information

**Risk：**Customers or consumers may not receive needed information

**Better approach：**Manage submission and supply-chain communication separately

Mistake：Using an SDS instead of article material data

**Risk：**Article-level concentration and part location may be missing

**Better approach：**Obtain material declarations mapped to parts

Mistake：Using testing instead of all supplier data

**Risk：**Sample coverage is incomplete and changes are unmanaged

**Better approach：**Combine traceable documentation with risk-based testing

Mistake：Not distinguishing recipient and consumer timing

**Risk：**The Article 33 response process fails

**Better approach：**Set delivery and 45-day consumer-request processes

Mistake：Ignoring Article 7’s one-tonne and intended-release conditions

**Risk：**An Article 33 conclusion is mistaken for registration/notification assessment

**Better approach：**Maintain a separate Article 7 decision record

Company action checklist

• Create an evidence-type-to-legal-question matrix
• Require material data by part number and revision
• Keep SDSs in the data flow where their legal conditions apply
• Set Article 33 customer-delivery and consumer-request processes
• Screen Article 7 using annual tonnage and release conditions
• Align SCIP data and the product tree where SCIP applies
• Use risk-based testing
• Retain applicable records and update history

Manager summary

An effective REACH evidence chain does not select the thickest document; it makes each record answer the correct legal question. Material data and declarations provide traceability, SDSs provide defined safety information, and testing resolves bounded uncertainty—while Article 33, Article 7 and SCIP remain separate decisions.

Frequently asked questions

What is the minimum Article 33 information?

For an article meeting the conditions, it includes at least the SVHC name and available information sufficient for safe use.

What is the consumer response deadline?

Article 33(2) requires the relevant information free of charge within 45 days of receipt of the request.

Does SCIP replace a customer declaration?

No. It is a separate submission to ECHA and does not replace Article 33 supply-chain communication.

Is material data always better than testing?

They answer different questions. Reliable, complete data can reduce testing, but gaps may still require testing.

When should Article 7(1) be considered?

When a substance in an article is intended to be released under normal or reasonably foreseeable conditions and annual quantity may exceed the threshold.

Official legislation and reference material

REACH Regulation (consolidated text)

EUR-Lex

• Legal status: Binding EU Regulation; consult the current EUR-Lex consolidated version

• Last checked: 2026-08-08

• Publication / update date: 2026-05-11 (current consolidation)

• Used for: Articles 7, 31, 33 and 36

Candidate List of substances of very high concern for Authorisation

European Chemicals Agency (ECHA)

• Legal status: Official current ECHA Candidate List

• Last checked: 2026-08-08

• Publication / update date: Current list page; 2026-02-04 update used for this review baseline

• Used for: SVHC entries and inclusion dates

Summary of obligations resulting from inclusion of SVHCs in the Candidate List

European Chemicals Agency (ECHA)

• Legal status: Official ECHA implementation summary; not a substitute for the Regulation

• Last checked: 2026-08-08

• Publication / update date: Publication/update date not stated on the linked official page; checked 2026-08-08.

• Used for: Article 7 notification and Article 33 communication

Safety data sheets

European Chemicals Agency (ECHA)

• Legal status: Official ECHA technical and supply-chain information

• Last checked: 2026-08-08

• Publication / update date: Publication/update date not stated on the linked official page; checked 2026-08-08.

• Used for: When SDSs apply and are updated

SCIP Database

European Chemicals Agency (ECHA)

• Legal status: Official ECHA Waste Framework Directive information

• Last checked: 2026-08-08

• Publication / update date: Publication/update date not stated on the linked official page; checked 2026-08-08.

• Used for: SCIP submission scope