SAFEGUARDS | Consumer Products NO. 156/16
On September 6, 2016, the European Chemical Agency (ECHA) launched the second public consultation  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)  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||
|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||
|4||Benzene-1,2,4-tricarboxylic acid 1,2-anhydride (trimellitic anhydride)||552-30-7 / 209-008-0||EQC||
|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||
|6||p-(1,1-dimethylpropyl)phenol||80-46-6 / 201-280-9||EQC||
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 www.sgs.com/reach.
For enquiries, please contact:
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