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SAFEGUARDS | Consumer Products NO. 007/17

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On January 12, 2017, the European Chemical Agency (ECHA) added four new Substances of Very High Concern (SVHC) to the Candidate List [1]. The addition of these new SVHCs brings the total number of entries to 173.

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 four new SVHCs added to the Candidate List is July 12, 2017.

Four New SVHC Candidates

Notably, one of the new SVHC candidates is bisphenol A which was reclassified from Repr. 2 to Repr. 1B in the 9th adaption of the technical and scientific progress (Regulation (EU) No 2016/1179) to CLP Regulation (EC) No 1272/2008 [2]. The use of bisphenol A is under close scrutiny for toys and food contact material in several countries [3], [4], [5]. Recently, the EU published a new law to restrict bisphenol A in thermal paper, under a new entry to Annex XVII of REACH. This will be effective from January 2, 2020 [6].

Nonadecafluorodecanoic acid (PFDA) and its sodium and ammonium salts is the eighth long-chain perfluorinated carboxylic acids included as an SVHC, owing to its proposed CLP classification as Repr. 1B and its PBT properties.

As a group of alkylphenols structurally similar to 4-nonylphenol and 4-tert-octylphenol, two phenols (p-(1,1-dimethylpropyl)phenol, and 4-heptylphenol, branched and linear) are included as SVHCs due to concerns that they may have serious effects on the environment.

Potential uses of the four new SVHCs are summarized in Table 1.

Table 1. Possible uses of the four new SVHCs in the Candidate List published by ECHA on January 12, 2017

No. Substance CAS No./
EC No.
Reason for inclusion Potential uses
1 4,4’-Isopropylidenediphenol (Bisphenol A) 80-05-7 / 201-245-8 Repr. 1B
  • Use as anti-oxidant for processing PVC
  • Use in epoxy resin hardeners, epoxy adhesives and encapsulants
  • Use for manufacturing thermal paper, polycarbonate, epoxy resins, coating materials
2 Nonadecafluorodecanoic acid (PFDA) and its sodium and ammonium salts 335-76-2; 3830-45-3; 3108-42-7 /  206-400-3; -; 221-470-5 Repr. 1B, PBT
  • Used as water, oil and soil repellent in textile, leather and paper
  • Used as stain and grease-proof coatings on food packaging, furniture upholstery and carpet
  • Used as component of fire-fighting foam
  • Used in nanosprays and impregnation sprays
  • Used as lubricant, wetting agent, plasticiser and corrosion inhibitor
3 p-(1,1-Dimethylpropyl)phenol 80-46-6 / 201-280-9 EQC
  • Used in the production of phenolic resins, ethoxylated resins and lacquers
  • Used as a germicide in cleaning solutions
  • Used in adhesive, sealants, coatings and paints, thinners and paint removes
  • Disulfide derivative as vulcanizing agent for the curing of rubber
4

4-Heptylphenol, branched and linear

[substances with a linear and/or branched alkyl chain with a carbon number of 7 covalently bound predominantly in position 4 to phenol, covering also UVCB- and well-defined substances which include any of the individual isomers or a combination thereof]

- / - EQC
  • Used as polymer intermediate
  • Formulation into lubricants

Abbreviations:

  • EQC: Equivalent level of concern
  • PBT: Persistent, bioaccumulative and toxic
  • Repr 1B: Toxic for reproduction Category 1B

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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