The German buyer wants REACH / SVHC: a CE file and a Responsible Person address will not do

Bottom line:

When a German customer says “REACH,” ask whether they want an SVHC statement, test data, or the SCIP their EU importer must file. Articles do not come with one official REACH pass certificate.
CE is product-safety conformity. The GPSR Responsible Person is an economic operator established in the Union. RoHS restricts certain substances in specified electrical goods. If those four are mixed, the factory sends a CE PDF and the next email still asks for composition.
A Hong Kong company opened a store. That does not issue a SCIP number, and it does not make you the EU importer. The factory sends composition and supplier statements. Filing usually sits with the buyer. The Candidate List is the current ECHA table.

The inquiry often says: “Please send REACH certificate and SCIP number.” The floor packs a CE file, a RoHS test and a two-year-old Chinese “no hazardous substances” letter. The buyer’s compliance person replies that this is not what they asked for. Finance then asks whether you should “register REACH” before the quote, and the price is already locked as “certification included.”

Whose name goes on the pack is on the GPSR Responsible Person. Tax numbers are a different sentence, on VAT / EORI. Embedded emissions for steel and aluminium are on the CBAM pack. Split the chemicals ask first: do they want composition, or an EU filing number you do not have.

1. One word, REACH, can mean five different files

REACH is Regulation (EC) No 1907/2006. On a lamp, a plastic part or a piece of hardware, the buyer’s one word may mean a statement, a test, a notification or a registration. If you answer “we have it” before you ask, the files will not match.

What they say	What they usually do with it	What a Hong Kong seller has ready
REACH / SVHC statement	Decide whether a Candidate List substance is above 0.1% w/w in the article	No official blank certificate. A written statement against the current list, plus tests or upstream statements if needed
A SCIP number	An EU supplier notifying ECHA when placing an SVHC-containing article on the market	A Hong Kong entity cannot take its own number. Send the data; the EU importer files
CE	Conformity under the applicable product-safety legislation	If you have it, send the EU declaration and the technical file. It does not answer SVHC
RoHS	Restriction of certain substances in specified electrical goods	If you have it, send the report for this appliance. A RoHS pass is not a finished REACH answer
Responsible Person / RP	The Union contact on the pack and the label	A Hong Kong address is not enough — see the Responsible Person page

The Candidate List is updated. A statement should name the date of the list and point to ECHA’s Candidate List. Do not keep a 2022 PDF under a new title. Do not freeze “how many substances” in the body — the count is the current table.

2. Above 0.1% in an article, the duty usually sits on the EU supplier

ECHA’s Candidate List obligations page says EU or EEA suppliers of articles must give customers enough information for safe use when a Candidate List substance is above 0.1% weight by weight. That is the Article 33 communication. There is no tonnage trigger. Ten lamps still count.

The same page describes another duty: an EU producer or importer may also have to notify ECHA when the substance in those articles is above 0.1% and the total exceeds one tonne per year, unless the use is already registered or exposure can be excluded. That is Article 7(2). It is not the same form as SCIP.

For a Hong Kong company the useful sentence is on ECHA’s note for non-EU companies: the non-EU manufacturer is not the importer. The EU importer may ask you for SVHC information. What you can do is name the substance, the concentration and the part. Filing and notification sit with the party established in the Union.

In a complex object the 0.1% is read per article, not as an average across the whole lamp or cabinet. Plasticisers in a cable, lead in a solder joint, a flame retardant in a housing — ask the upstream supplier for each. “The whole lamp is free of it” with no breakdown will not pass the buyer’s compliance colleague.

3. A Hong Kong company cannot take a SCIP number. The factory sends composition

SCIP is the database under the Waste Framework Directive. From 5 January 2021, suppliers who place on the EU market articles containing a Candidate List SVHC above 0.1% w/w submit information to ECHA. The official pages are SCIP and who must submit: EU producers and assemblers, EU importers, EU distributors and others who place the article on the market.

A non-EU supplier of articles cannot file in its own name and cannot obtain a SCIP number for its own legal entity. If the buyer wants “your SCIP,” reply that the number sits with the EU importer. You can send article identifiers, parts, substance names, concentration ranges and safe-use notes so they can file.

A factory-lab test is a data pack, not a registration. Paying a more expensive lab does not create an ECHA account. Lab fees sit in the lab contract. There is no site-wide official euro price. Do not write a chat quote into Trade Assurance as an official fee.

If you sell a substance or a mixture — paint, adhesive, cleaner — the path is not the article path. Registration, labelling and a safety data sheet may apply. Do not reuse an article SVHC template on a drum of chemicals. Finished goods on Alibaba.com follow the article path above. Chemicals need their own substance list.

4. An Only Representative is not the name on the pack

The Only Representative in REACH Article 8 is a natural or legal person established in the EU, appointed by a non-EU manufacturer, who takes on certain registration and notification duties that would otherwise sit on importers. It is aimed at substances, mixtures and the duties the regulation names. Appointing an OR does not make you the EU importer, and it does not let you print a Hong Kong secretary address on the pack.

The GPSR Responsible Person handles product-safety tasks: working with market surveillance, keeping the technical file, being the in-Union contact. Two contracts, two qualifications. If one email asks for REACH and a Responsible Person, split the reply: how composition is sent, and who will be the Responsible Person. Why a Hong Kong address is not enough is still that page.

Tax numbers split the same way. VAT and EORI answer import VAT and the customs ID. SCIP answers the waste database. IOSS answers a parcel the platform has already taxed. A Hong Kong commercial invoice does not fill those four boxes.

5. How to walk a lamp BOM with upstream

On electrical goods, lighting and small appliances, the buyer often does not want “one pass certificate for the whole lamp.” They want a parts list that can be taken apart. Finance and the floor can walk this before anyone pays to “register.”

Open the BOM: driver, lamp holder, plastic housing, power cord, plug, screws, potting compound, ink and labels. For each line ask the upstream supplier three things: what materials sit in this part, whether there is a statement or test against the current Candidate List, and the date of that statement. Mark the gaps. Do not write “the whole lamp is free of SVHCs” over a yellow row.

Cords and plugs are usually bought in. A RoHS file is not the REACH question: plasticisers and flame retardants, whether they sit on the Candidate List, and whether they sit above 0.1%. Recycled housings are harder for upstream to cover. Write “recycled source still open.” Do not put an old virgin-material report on top.

If the list is updated mid-order: the statement you already sent should keep its list date. Whether a newly added substance hits unshipped lots only, or also goods already on the water, is a written confirmation with the buyer. Do not silently swap a new PDF and leave the date unchanged.

If they send a group template with extra fields — article identifiers, a TARIC class, safe use — fill what you can. Write that the EU importer completes the rest in the capacity of the person placing the article on the market. Do not invent a SCIP number to fill a cell.

A tube of glue or a bottle of cleaner packed with the lamp is a mixture, not the lamp as an article. Keep the safety data sheet and the article statement apart. Do not bind them as one “REACH certificate.”

6. The packs the floor most often sends by mistake

Renaming a CE declaration “REACH.” That declaration lists low voltage or EMC. The buyer’s table wants substance names and concentrations. A new title will not pass. Send the CE file if it is due, and send composition separately.

A RoHS pass, then “chemicals are fine.” RoHS restricts certain substances in electrical goods. The REACH Candidate List is longer and it moves. Plasticisers in a moulding or auxiliaries in a textile are often not even in the RoHS report.

A one-page supplier “guarantee” with no substance and no list date. Upstream should write which Candidate List date, which parts, detected or not, and the method. An empty guarantee will not attach to the importer’s SCIP file.

One average for the whole lamp. 0.1% is read per article. If the housing passes and the cable does not, a whole-lamp statement is false. Have the floor break the BOM: which part, which upstream, which test.

“EU registered / REACH certified” on the showcase. Without a filing entity, that is a promise. After the order they will ask for the number. If you write anything, write that you can send composition and supplier statements, and that the EU importer files as ECHA requires.

7. Replies that hold up

What they ask	A reply that holds	Do not send
Send the REACH certificate and SCIP number.	Please confirm whether you need an SVHC statement, a test, or SCIP as the importer. We are the Hong Kong seller. SCIP is filed by the EU importer. We can prepare composition and a parts list against the current Candidate List.	CE is REACH. We will take a SCIP number on the Hong Kong licence.
Do you have an EU REACH registration number?	Finished goods follow the article communication and the importer’s notification. Not every factory registers a number. If this consignment is a substance or mixture, we treat the SDS and any OR separately.	Yes — it is our CE number / Hong Kong company number.
The web says every EU export must register REACH first.	Registration of substances and mixtures, article communication and SCIP are not the same path. This is a finished-goods order from a Hong Kong company. We send composition for the article. Filing follows who imports.	Fine, we will pay for a registration before we quote.
Print your Hong Kong address as Responsible Person, and that covers REACH.	The Responsible Person must be established in the Union. A REACH OR is a different appointment. A Hong Kong address fills neither.	Fine — print the secretary address.

On FOB or CIF bulk, the importer is usually the EU buyer. Your commercial invoice and composition file do not make you the REACH importer. If the seller is to take the placing-on-the-market filing, the contract has to name the importer — that is already close to DDP, on DDP / DAP.

8. If you already wrote “we have REACH”

Tell sales the same day: stop sending totals marked “certified.” That chat line does not count.
Ask the buyer whether they want an SVHC statement, a test report, a SCIP number, or an OR / Responsible Person. Collect those four in separate mails.
Open the current Candidate List and walk the BOM with the floor and upstream. Do not promise “the whole lamp is free of it” on parts you have not checked.
Keep CE, RoHS, the Responsible Person and tax numbers in their own files. Do not merge them into one renamed PDF.
If they still want a SCIP in your name: write that the number sits with the EU importer. You send data. You do not file, and you do not put the platform IOSS in that box.
If the goods are already on the water: send composition that matches this lot. Do not rewrite origin or invent a filing number to “help clearance.”

The membership fee still only buys the file and the showcases. It wires to ALIBABA.COM HONG KONG LIMITED. Corpable does not file at ECHA and does not guarantee a substance conclusion. How the importer files, and how customs or market surveillance read the file, follow those authorities.

Questions teams actually ask

We have a CE certificate. Does that mean we already meet REACH?

No. CE sits under the product-safety legislation that applies — low voltage, EMC and the rest. REACH sits on substances, mixtures and substances in articles. A CE declaration does not answer whether a Candidate List SVHC is present.

We opened Alibaba.com on a Hong Kong company. Can we file SCIP at ECHA ourselves?

SCIP is filed by an EU supplier who places the article on the Union market — usually the EU producer, importer or distributor. A Hong Kong company is not established in the EU and cannot take a SCIP number in its own name. The factory sends composition; the buyer or their importer files.

The buyer wants a “REACH certificate.” Where do we get one?

There is no single official REACH pass certificate for articles. What you usually prepare is an SVHC statement against the current Candidate List, tests or supplier statements where needed, and the EU importer’s own SCIP. Renaming an old list PDF is not a registration.

Is an Only Representative the same as the GPSR Responsible Person?

No. An OR is the EU person a non-EU manufacturer appoints under REACH for substance or mixture duties. The GPSR Responsible Person handles product-safety tasks. Two statutes, two contracts. A secretary address fills neither.

May the showcase say “REACH / RoHS certified”?

Not without a statement and tests that match the product. RoHS only restricts certain substances in specified electrical goods. It is not REACH. “Certified” will be screenshotted back at you.

Can Corpable register us under REACH or guarantee a part is free of SVHCs?

No. An advisor can sit with you on whether they want a statement, a test or SCIP. We do not file at ECHA and we do not guarantee composition. Tests and filings follow the lab contract, the importer and ECHA.