Hyderabad Dye Intermediate Manufacturer Navigates REACH SVHC and Reformulates for EU

Curated by Vinod Kumar Jain & Amit Jain · All Frontier Global · free, no login

India-EU

Challenge

A Hyderabad-based dye intermediates manufacturer had been supplying EU textile dye manufacturers for 5 years. A routine ECHA Candidate List update added a chemical intermediate they manufactured to the SVHC list. The EU buyers immediately issued Article 33 notification requests — asking the Indian manufacturer to confirm whether their products contained the SVHC above 0.1%. The manufacturer was unsure of the SVHC content in their products and had no REACH compliance team.

Solution

AJG connected the manufacturer with a Mumbai-based REACH compliance consultant. Product analysis confirmed that the SVHC was present at 0.3% — above the 0.1% threshold. Two options were evaluated: (1) continue supplying with Article 33 notification (legal but EU buyers may de-list); (2) reformulate to eliminate the SVHC. The reformulation route was chosen — a technical programme to substitute the SVHC with a non-listed equivalent. Reformulation completed in 9 months. Reformulated product tested and confirmed SVHC-free.

Outcome

Reformulated SVHC-free product launched at month 10. All 4 EU buyers retained. Two additional EU buyers won on the basis of proactive SVHC-free product positioning. Annual EU revenue grew from EUR 2.8M to EUR 3.9M. The company now maintains a continuous REACH monitoring programme to anticipate future SVHC additions.

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