ECHA has recently added seven new substances of very high concern (SVHCs) to the REACH Candidate List, bringing the total number of substances included on the list to 181. In addition to this, Bisphenol A (BPA) – a synthetic chemical commonly used in the manufacture of plastics and resins – has had its entry on the list updated to reflect its endocrine disrupting properties causing adverse effects to the environment.
Substances of Very High Concern (SVHCs)
When a substance is identified as an SVHC – and subsequently placed on the Candidate List – companies who supply the substance – on its own, in a mixture or when contained in articles – may have IMMEDIATE legal obligations.
Suppliers of articles containing SVHCs in concentrations greater than 0.1% (w/w) must provide recipients who will use or handle the article with adequate information to ensure safe use. There are also conditions under which suppliers of articles on the Candidate List must submit a notification to ECHA.
Companies supplying chemical substances included on the Candidate List must provide a safety data sheet (SDS). Even in instances where chemical mixtures are not classified as hazardous themselves but INCLUDE substances on the Candidate List, suppliers must be able to provide an SDS when requested.
Substances included on the Candidate List are prioritised when ECHA consider substances for inclusion on the Authorisation List, contained in Annex XIV of REACH. If a substance is ultimately added to the Authorisation List, chemical manufacturers, chemical importers and downstream users must seek approval before using or placing it on the market.
Which SVHCs have been added to the Candidate List?
The seven substances, along with some examples of their uses, are as follows:
- Chrysene [CAS number 218-01-9]: Normally not produced intentionally but rather occurs as a constituent or impurity in other substances, chrysene has been added to the list due to being Carcinogenic, as well as for its Persisent, Bioaccumulative and Toxic (PBT) and very Persistent and very Bioaccumulative (vPvB) properties.
- Benz[a]anthracene [CAS number 56-55-3]: As with Chrysene, this substance is normally not produced intentionally but occurs as a constituent or impurity in other substances, and has been added to the list due to being Carcinogenic, as well as for its PBT and vPvB properties.
- Cadmium nitrate [CAS number 10325-94-7]: Used for the manufacture of glass, porcelain and ceramic products, as well as in laboratory chemicals, this substance has been added to the Candidate List due to its Carcinogenic, Mutagenic and Specific Target Organ Toxicity after Repeated Exposure (STOT RE) properties.
- Cadmium hydroxide [CAS number 21041-95-2]: Used for the manufacture of electrical, electronic and optical equipment, as well in laboratory chemicals, this has also been added to the list due to its Carcinogenic, Mutagenic and STOT RE properties.
- Cadmium carbonate [CAS number 513-78-0]: Used as a pH regulator and in water treatment products, laboratory chemicals, cosmetics and personal care products, this chemical has also been added to the list for its Carcinogenic, Mutagenic and STOT RE properties.
- 1,6,7,8,9,14,15,16,17,17,18,18- Dodecachloropentacyclo[18.104.22.168,9.02,13.05,10]octadeca-7,15-diene (“Dechlorane Plus”TM) (covering any of its individual anti- and syn-isomers or any combination thereof) [No CAS number]: Used as a non-plasticising flame retardant, used in adhesives, sealants and in binding agents, this has been added to the Candidate List due to its vPvB properties.
- Reaction products of 1,3,4-thiadiazolidine-2,5-dithione, formaldehyde and 4-heptylphenol, branched and linear (RP-HP) [with ≥1% w/w 4-heptylphenol, branched and linear [No CAS number]: Used as a lubricant additive in lubricants and greases, these reaction products have been added for their endocrine disrupting properties.
Bisphenol A (BPA) update
ECHA has also updated the Candidate List entry for BPA to reflect an additional reason for inclusion, prompted by ECHA’s Member State Committee upholding a proposal from Germany in a meeting at the end of last year. The updated entry now includes the compound’s endocrine disrupting properties causing adverse effects to the environment.
BPA is used in the manufacture of polycarbonate, as a hardener for epoxy resins, as an anti-oxidant for processing PVC, and in thermal paper production. Although it has often been cited as a “controversial chemical”, it is found in many household items, including plastic bottles, food storage containers, canned foods, children’s toys, and even shop receipts.
Last month, Members of the European Parliament (MEPs) voted against the proposal of a total ban on BPA in food contact materials. However, a draft European Commission regulation that lowers the amount of BPA allowed to migrate into or onto food from packaging materials is expected to be finalised in the coming months.
ECHA regularly assesses substances on the Candidate List for inclusion in the REACH Authorisation List. Substances which are ultimately added to the Authorisation List cannot be placed on the market or used after a given date unless they meet specific authorisation requirements.
If you are a manufacturer or importer of any of these SVHCs, you should be aware of the potential legal implications for your business. At UL Safeware Quasar we have a dedicated team of expert Regulatory Consultants who have a comprehensive understanding of chemical regulations across the globe, and are constantly monitoring the regulations to help hundreds of companies sustain chemical compliance.
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