SAFEGUARDS | Consumer Products NO. 058/16


On 29 February 2016, European Chemical Agency (ECHA) launched a new consultation list of proposed Substances of Very High Concern (SVHC) [1]. The first SVHC consultation list of 2016 includes four proposals. The SVHCs candidate list will expand to 172 if the four proposals are accepted. Interested parties have until April 14 2016 to submit comments and further information on use, exposure, alternatives and risks of the substances to the agency.



The first two substances are camphor derivates that are included based on structural similarities to camphor suggesting an equivalent level of concern about probable serious effects to the environment.  They are used as UV filter in cosmetics and sun screen products.

Another substance is Benzo[def]chrysene (IUPAC name: Benzo[a]pyrene) which belongs to the substance group of Polycyclic Aromatic Hydrocarbons (PAHs). Some members of this substance group are well known to be human carcinogens.

The fourth 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.

SVHC may be introduced into consumer products at many stages of the production process. Due to the complexities of both the supply chain and production processes, the presence of SVHC in a product may not be declared by suppliers. Identifying high risk products or materials and having a test strategy can 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

Table 1. Possible uses of 4 potential substances of very high concern published by ECHA on 29 February 2016

No. Substance CAS No. / EC No. Classification Potential uses
1 (±)-1,7,7-trimethyl-3-[(4-methylphenyl)methylene] bicyclo[2.2.1]heptan-2-one (4-methylbenzylidene camphor) 36861-47-9 / 253-242-6 Equivalent level of concern having probable serious effects to the environment
  • Used as UV filter in cosmetics and sun protection agents.
2 1,7,7-trimethyl-3-(phenylmethylene) bicyclo[2.2.1]heptan-2-one (3-Benzylidenecamphor) 15087-24-8 / 239-139-9
3 Benzo[def]chrysene (Benzo[a]pyrene) 50-32-8 / 200-028-5 CMR, PBT, vPvB
  • No specific function as it is contaminant upon production of plastic, rubber, coatings and it is particularly found in extender oils and carbon black.
4 Dicyclohexyl phthalate 84-61-7 / 201-545-9 Toxic for reproduction; Equivalent level of concern having probable serious effects to human health and the environment
  • Used as plasticisers in plastisol and in PVC, rubber and plastic articles.
  • Used as phlegmatizer and as a dispersing agent for formulations of organic peroxides.
  • Used in fillers, putties, plasters and modelling clay.
  • Used in adhesives, sealants, coatings and paints, thinners, paint remover and finger paints.


CMR: Carcinogenic, Mutagenic, Toxic for reproduction

PBT: Persistent, bioaccumulative and toxic.

vPvB: Very persistent and very bioaccumulative;


For enquiries, please contact:

Corey So
Corporate Research and Development 
t: +852 2774 7150 ext. 1150


Stay on top of regulatory changes within your industry: subscribe to SafeGuardS!



© SGS Group Management SA - 2016 - All rights reserved - SGS is a registered trademark of SGS Group Management SA. This is a publication of SGS, except for 3rd parties’ contents submitted or licensed for use by SGS. SGS neither endorses nor disapproves said 3rd parties contents. This publication is intended to provide technical information and shall not be considered an exhaustive treatment of any subject treated. It is strictly educational and does not replace any legal requirements or applicable regulations. It is not intended to constitute consulting or professional advice. The information contained herein is provided “as is” and SGS does not warrant that it will be error-free or will meet any particular criteria of performance or quality. Do not quote or refer any information herein without SGS’s prior written consent.