SAFEGUARDS | Consumer Products NO. 156/16

SafeGuardS chemicals

On September 6, 2016, the European Chemical Agency (ECHA) launched the second public consultation [1] of 2016 on six potential Substances of Very High Concern (SVHC). The SVHCs candidate list will expand to 175 if all the six proposals are accepted. Interested parties have until October 21, 2016 to submit comments and further information on the use, exposure, alternatives and risks of the substances to the ECHA.

The Six Potential SVHC Proposals

Six SVHC proposals were published in the second consultation list of 2016, one of which is notably bisphenol A. Bisphenol A was reclassified from Repr. 2 to Repr. 1B in 9th adaption of the technical and scientific progress (Regulation (EU) NO. 2016/119) [2] to CLP Regulation (EC) NO. 1272/2008, and therefore fulfills the criteria for identification of SVHC in accordance with REACH. Currently, the use of bisphenol A is strictly regulated at a global level in certain toys and food contact materials; it is proposed to also restrict its presence in thermal paper under Annex XVII of REACH.

Being a group of alkylphenols with a linear or branched alkylchain in para-position as SVHC candidates, 4-nonylphenol and 4-tert-octylphenol, three phenols (4-tert-butylphenol, p-(1,1-dimethylpropyl)phenol, and 4-heptylphenol, branched and linear) are proposed as SVHCs due to equivalent level of concern based on their endocrine disrupting properties. The three phenols are generally used in the production of polymers and resins.

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

The sixth proposed SVHC is a respiratory sensitizer, trimellitic anhydride, which is mainly used in the manufacture of polymers, esters, and epoxy resins.

The potential uses of the six potential SVHCs are summarized in Table 1.

Table 1: Possible uses of the potential SVHCs in the Consultation List published by ECHA on September 6, 2016

No Substance CAS No./ EC No. Classification Potential uses
1 4,4’-Isopropylidenediphenol (Bisphenol A) 80-05-7 / 201-245-8 Repr. 1B
  • As anti-oxidant for processing
  • PVC In epoxy resin hardeners, epoxy adhesives and encapsulants
  • For manufacturing thermal paper, polycarbonate, epoxy resins, coating materials
2 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 As a polymer intermediate
3 4-tert-butylphenol 98-54-4 / 202-679-0 EQC
  • In the production of phenolic resins, ethoxylated resins, epoxy resins and polycarbonates
  • As an antioxidant and stabilizer in rubber, plastic, food and oils
  • As a raw material for construction elements and floors in buildings
4 Benzene-1,2,4-tricarboxylic acid 1,2-anhydride (trimellitic anhydride) 552-30-7 / 209-008-0 EQC
  • As a synthesis of plasticizer in PVC resin
  • As a reactant in wire and cable insulation enamels and polyester resins in powder coatings
  • As an epoxy curing agent, textile sizing agent, rubber curing accelerator, electrostatic toner binder, and vinyl cross-link agent
5 Nonadecafluorodecanoic acid (PFDA) and its sodium and ammonium salts 3108-42-7; 335-76-2; 3830-45-3 / 221-470-5; 206-400-3; Repr. 1B, PBT
  • As water, oil and soil repellent in textiles, leather and paper
  • As stain and grease-proof coatings on food packaging, furniture upholstery and carpet
  • As a component of fire-fighting foam
  • In nanosprays and impregnation sprays
6 p-(1,1-dimethylpropyl)phenol 80-46-6 / 201-280-9 EQC
  • In the production of phenolic resins, ethoxylated resins and lacquers
  • As a germicide in cleaning solutions
  • In adhesive, sealants, coatings and paints, thinners and paint removes
  • Disulfide derivative as vulcanizing agent for the curing of rubber


EQC: Equivalent level of concern

PBT: Persistent, bioaccumulative and toxic

Repr 1B: Toxic for reproduction Category 1B

SVHC 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 visit

For enquiries, please contact:

Emily Lam

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

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