SAFEGUARDS | Consumer Products NO. 156/15

On September 1, 2015, European Chemical Agency (ECHA) launched a new consultation list of Substances of Very High Concern (SVHC). [1] The second SVHC consultation list of 2015 includes seven proposals. The SVHCs candidate list will expand to 170 entries if all seven proposals are accepted. Interested parties have until October 15, 2015 to submit comments and additional information to the agency about use, exposure, alternatives and risks of the substances.

The 7 Potential SVHCs

Seven SVHCs were placed on the consultation list on September 1, 2015. Following the inclusion of 2-benzotriazol-2-yl-4,6-di-tert-butylphenol (UV-320) and 2-(2H-benzotriazol-2-yl)-4,6-ditertpentylphenol (UV-328) last year, two additional UV filters were included this time, due to concerns about their very persistent and very bioaccumulative properties. The newly proposed substances 2,4-di-tert-butyl-6-(5-chlorobenzotriazol-2-yl)phenol (UV-327) and 2-(2H-benzotriazol-2-yl)-4-(tert-butyl)-6-(sec-butyl)phenol (UV-350) are used as UV-protection agents in coatings, plastics, rubber and polyurethanes.

The third substance is a plasticiser in plastisol and in PVC, rubber and plastic articles; Dicyclohexyl phthalate will be the fifteenth phthalate in SVHC list if the proposal is accepted.

The fourth substance is Perfluorononan-1-oic acid (PFNA). PFNA is an analogue of Perfluorooctanoic acid (PFOA). PFNA is similar to PFOA in physicochemical, toxicological and ecotoxicological properties. The  three other substances are chemical intermediates including nitrobenzene, hexamethylene diacrylate and 1,3-propanesultone.

SVHC may be introduced into various consumer products due to the complexities of both the supply chain and production process. Laboratory testing provides reliable evidence to determine if chemical substances exist in products and information on their volume and concentration.  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 visit SGS REACH website.

Table 1. Examples of possible uses of 7 potential substances of very high concern published by ECHA on September 1, 2015.

Table 1 



CAS No./

EC No.


Potential uses



1120-71-4 /  214-317-9

Carc. 1B

  • - Used as an intermediate in the manufacture of fine and bulk chemicals.
  • - Used as a pre-product to manufacture aqueous polyurethane dispersions.
  • - Used as pre-product for the manufacture of light-sensitive dyes for photographic and radiographic films.
  • - Use in the electrolyte fluid in the production of lithium ion batteries.


2,4-di-tert-butyl-6-(5-chlorobenzotriazol-2-yl)phenol (UV-327)

3864-99-1 / 223-383-8


  • - Used as UV-protection agents in coatings especially for cars and special industrial wood coatings.
  • - Used as UV-protection agents for plastics, rubber and polyurethanes.
  • - Used in cosmetics as sun protection agents.


2-(2H-benzotriazol-2-yl)-4-(tert-butyl)-6-(sec-butyl)phenol (UV-350)

36437-37-3 / 253-037-1



Dicyclohexyl phthalate

84-61-7 / 201-545-9

Repr. 1B / EQC

  • - Used as a plasticiser in plastisol and in PVC, rubber and plastic articles.
  • - Used as phlegmatizer and dispersing agent for formulations of organic peroxides.
  • - Used in fillers, putties, plasters and modelling clay
  • - Used in adhesives, sealants, coatings and paints, thinners, paint removes and finger paints.


Hexamethylene diacrylate (hexane-1,6-diol diacrylate)

13048-33-4 / 235-921-9


  • - Used in manufacturing of formulations of coatings and inks.
  • - Used as a cross linking agent in polymerization processes in production of resins, rubbers, polymers.
  • - Used as coatings for furniture & flooring and industrial applications.



98-95-3 / 202-716-0


Repr. 1B

  • - Used as an intermediate under strictly controlled conditions (SCC).
  • - Use as processing aid and as a solvent for the preparation of formulations.


Perfluorononan-1-oic acid (2,2,3,3,4,4,5,5,6,6,7,7,8,8,9,9,9-heptadecafluorononanoic acid and its sodium and ammonium salts)




/ 206-801-3

Repr. 1B / PBT

  • - Used as a processing aid for the fluoropolymer manufacture, most notably for polyvinylidene fluoride.
  • - Used as lubricating oil additive, surfactant for fire extinguishers, cleaning agent, textile antifouling finishing agent, polishing surfactant, waterproofing agents and in liquid crystal display panels.


Carc. 1B: Carcinogen category 1B;

vPvB: Very persistent and very bioaccumulative;

Repr. 1B: Toxic for reproduction category 1B;

EQC: Equivalent level of concern;

PBT: Persistent, bioaccumulative and toxic.

For enquiries, please contact:

Jason Wong
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