On January 15, 2018, ECHA added seven new SVHCs to the Candidate List that expands the total number to 181 entries. The BPA entry is also updated to include its endocrine disrupting properties for the environment.

SAFEGUARDS | Consumer Products NO. 006/18

On January 15, 2018, the European Chemical Agency (ECHA) added seven new Substances of Very High Concern (SVHCs) to the Candidate List and updated the Bisphenol A (BPA) entry by inclusion of its endocrine disrupting properties that has equivalent level of concern (EQC) causing probable serious effects to the environment [1]. The addition of the new SVHCs brings the total number of entries to 181.

Obligations for article producers and importers

According to Article 33 of REACH, European Union (EU) and European Economic Area (EEA) manufacturers and importers of articles are required to provide information to allow the safe use of products by the recipients upon supply, and to consumers within 45 days upon request, when the concentration of the SVHC in the article exceeds 0.1% (w/w). For articles that contain an SVHC in which the concentration is above 0.1% with the quantity over one tonne per year, a notification shall be submitted to ECHA by the manufacturers or the importers under Article 7 of REACH. The notification of SVHCs in an article shall be made within six months of their inclusion on the List. The notification deadline for the one new SVHC added to the Candidate List is July 15, 2018.

Seven new SVHC candidates

Two of the new SVHCs are two polyaromatic hydrocarbons (PAHs) - benz[a]anthracene and chrysene, which are classified as Carc. 1B and having PBT and vPvB properties. They are not produced intentionally but occur together with other PAHs as constituent of coal and petroleum stream UVCB substances. Two PAHs benzo[a]pyrene (B[a]P) and anthracene are already included on the Candidate List due to CMR, PBT and vPvB properties.

Three substances are cadmium compounds - cadmium nitrate, cadmium carbonate and cadmium hydroxide, which are classified as Carc. 1B, Muta. 1B and substances causing damage to kidney and bone after prolonged exposure (STOT RE 1). These cadmium compounds may be used as alternatives to each other and their wide range of potential uses include, but not limited to, manufacture of electrical equipment, electronics, plastics, glass, ceramics and paper products.

The remaining two substances are UVCBs, which are non-plasticizing flame retardant Dechlorane PlusTM and corrosion inhibitor, reaction products of 1,3,4-thiadiazolidine-2,5-dithione, formaldehyde and 4-heptylphenol, branched and linear (RP-HP). Dechlorane PlusTM includes its anti- and syn- isomers or any combination thereof, and is considered to be vPvB. The application of Dechlorane PlusTM such as in plastics, cables, automobile parts, connectors, adhesives and binding agent. RP-HP contains 0.1% w/w 4-heptylphenol, branched and linear (4-HPbl) and therefore considered to be endocrine disruptors for the environment. 4-HPbl belongs to a group of structurally similar 4-alkylphenols and is already on the Candidate List for the same reason.

BPA entry update

BPA has been included in the SVHC Candidate List based on its classification of Repr. 1B and its endocrine disrupting properties with serious effects to human health. The current update is to amend the reason for including BPA on the candidate list by adding endocrine disrupting properties with serious effects to the environment.

The potential uses of the seven new SVHCs and BPA are summarized in Table 1.

Table 1. Possible uses of the seven new SVHCs and BPA on the Candidate List published by ECHA on January 15, 2018

No.
 Substance
 CAS No./
EC No.
 Classification
 Potential uses
1
 4,4'-Isopropylidenediphenol (Bisphenol A)
 80-05-7/201-245-8
 ED(environment)
  • Anti-oxidant for processing PVC
  • Use in epoxy resin hardening, epoxy adhesives and encapsulants
  • Manufacture of thermal paper, polycarbonate, epoxy resins, coating materials
2
 Benz[a]anthracene
 56-55-3/200 280-6
 Carc. 1B, PBT, vPvB
  • Not produced intentionally but occurs as a constituent or impurity in coal and petroleum stream substances
3
 Cadmium carbonate
 513-78-0/513-78-0
 Carc. 1B, Muta. 1B, STOT RE 1
  • pH regulator
  • Use in water treatment products, laboratory chemicals, cosmetics and personal care products
  • Manufacture of plastics for food packaging and storage, toys, mobile phones and coatings for cable
  • Additive for glass
4
 Cadmium hydroxide
 21041-95-2/244-168-5
 Carc. 1B, Muta. 1B, STOT RE 1
  • Use in laboratory chemicals
  • Manufacture of electrical, electronic and optical equipment
  • Manufacture of flooring, furniture, toys, construction materials, curtains, footwear, leather products, paper and cardboard products
5
 Cadmium nitrate
 10325-94-7/233-710-6
 Carc. 1B, Muta. 1B, STOT RE 1
  • Use in laboratory chemicals
  • Manufacture of glass, porcelain and ceramic products
6
 Chrysene
 218-01-9/205-923-4
 Carc. 1B, PBT, vPvB
  • Not produced intentionally but occurs as a constituent or impurity in coal and petroleum stream substances
7
 1,6,7,8,9,14,15,16,17,17,18,18-Dodecachloropentacyclo[12.2.1.16,9.02,13.05,10]octadeca-7,15-diene
(Dechlorane PlusTM) [covering any of its individual anti- and
syn-isomers or any combination thereof]
 -
 vPvB
  • Non-plasticizing flame retardant for plastics, electronic wiring and cables, automobiles, hard plastic connectors and plastic roofing material
  • Use in adhesives and sealants
  • Use in binding agents
8
 Reaction products of 1,3,4-thiadiazolidine-2,5-dithione, formaldehyde and 4-heptylphenol, branched and linear (RP-HP) [with ≥0.1% w/w 4-heptylphenol, branched and linear]
 -
 ED (environment)
  • Corrosion inhibitors in lubricant additives, lubricants and greases

Abbreviations

Carc. 1A: Carcinogenicity category 1A

Carc. 1B: Carcinogenicity category 1B

CMR: Carcinogenic, mutagenic, and toxic for reproduction

ED: Endocrine disrupting properties

Muta. 1B: Germ cell mutagenicity category 1B

PBT: Persistent, bioaccumulative and toxic

STOT RE 1: Specific target organ toxicity after repeated exposure

UVCBs: Substance of unknown or variable composition, complex reaction products or biological materials

vPvB: Very persistent and very bioaccumulative

Comments and further information on use, exposure, alternatives and risks of the substances shall be submitted by July 15, 2018.

SVHCs may be introduced into various consumer products due to the complexities of both the supply chain and production process. Identifying high risk products or materials, or having a test strategy, can also be a smart way to ensure compliance and save costs. If you would like to learn more about how SGS can support your REACH compliance activities please contact us at reach@sgs.com or visit www.sgs.com/reach

For enquiries, please contact:

Emily Lam

Corporate Research & Development
t: +852 2204 8339 ext.1339

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