SAFEGUARDS | Consumer Products NO. 148/17

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On September 5, 2017, European Chemical Agency (ECHA) launched the second 2017 public consultation on nine potential Substances of Very High Concern (SVHCs) [1]. The Candidate List will expand to 182 if these proposals are accepted. Interested parties have until October 20, 2017 to submit comments and further information on use, exposure, alternatives and risks of the substances to ECHA.

The nine potential SVHC proposals

Nine SVHC proposals were published in the first consultation list of 2017 list, one being bisphenol A (BPA) which has been highly publicized. BPA has been included in the SVHC Candidate List based on its classification of Repr. 1B and its endocrine disrupting properties with serious effects to human health. The current proposal updates the reason for including BPA on the candidate list by adding endocrine disrupting properties with serious effects to the environment.

Two further SVHC proposals are benz[a]anthracene and chrysene, which are polyaromatic hydrocarbons (PAHs) and are considered for inclusion due to their classification as Carc. 1B and their PBT and vPvB properties. They are not produced intentionally but occur together with other PAHs as constituents of coal and petroleum stream UVCB substances. Two PAHs benzo[a]pyrene (B[a]P) and anthracene are already included on the Candidate List due to CMR, PBT and vPvB properties.

Three substances are cadmium compounds – cadmium nitrate, cadmium carbonate and cadmium hydroxide, which are proposed to be identified as SVHC candidates based on their classification as Carc. 1B, Muta. 1B and substances causing damage to kidney and bone after prolonged exposure (STOT RE 1). These cadmium compounds may be used as alternatives to each other and their wide range of potential uses include, but are not limited to, manufacture of electrical equipment, electronics, plastics, glass, ceramics and paper products.

Tricobalt tetraoxide is another inorganic compound on the consultation list for classification as Carc. 1A with ≥ 0.1% w/w nickel oxides as impurity. This substance has various uses such as pH regulator, manufacture of semiconductors, polymers, pigments, decoloring glass and coatings.

The remaining two substances are UVCBs, which are non-plasticizing flame retardant Dechlorane PlusTM and corrosion inhibitor, reaction products of 1,3,4-thiadiazolidine-2,5-dithione, formaldehyde and 4-heptylphenol, branched and linear (RP-HP). Dechlorane PlusTM includes its anti- and syn- isomers or any combination thereof, and is considered to be vPvB. The application of Dechlorane PlusTM such as in plastics, cables, automobile parts, connectors, adhesives and binding agent. RP-HP is proposed to be identified as SVHC candidate for containing 0.1% w/w 4-heptylphenol, branched and linear (4-HPbl) as endocrine disruptors for the environment. 4-HPbl belongs to a group of structurally similar 4-alkylphenols and is already on the Candidate List for the same reason.

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

Table 1. Possible uses of the potential SVHCs in the Consultation List published by ECHA on September 5, 2017

CAS No./EC No.  Classification
Potential uses
octadeca-7,15-diene (Dechlorane PlusTM)
[covering any of its individual anti- and syn-isomers
or any combination thereof]
  • Non-plasticizing flame retardant for plastics, electronic wiring and cables, automobiles, hard plasticconnectors and plastic roofing material
  • Use in adhesives and sealants
  • Use in binding agents
4,4’-Isopropylidenediphenol (Bisphenol A)
ED (environment)
  • Anti-oxidant for processing PVC
  • Use in epoxy resin hardeners, epoxy adhesives and encapsulants
  • Manufacture of thermal paper, polycarbonate, epoxy resins, coating materials
Carc. 1B, PBT, vPvB
  • Not produced intentionally but occurs as a constituent or impurity in coal and petroleum stream substances
Cadmium nitrate
Carc. 1B, Muta. 1B, STOT RE 1
  • Use in laboratory chemicals
  • Manufacture of glass, porcelain and ceramic products
Cadmium carbonate
Carc. 1B, Muta. 1B, STOT RE 1
  • pH regulator
  • Use in water treatment products, laboratory chemicals, cosmetics and personal care products
  • Manufacture of plastics for food packaging and storage, toys, mobile phones and coatings for cable
  • Additive for glass
Cadmium hydroxide
Carc. 1B, Muta. 1B, STOT RE 1
  • Use in laboratory chemicals
  • Manufacture of electrical, electronic and
    optical equipment.
  • Manufacture of flooring, furniture, toys, construction materials, curtains, footwear, leather products, paper and cardboard products
Carc. 1B, PBT, vPvB
  • Not produced intentionally but occurs as a constituent or impurity in coal and petroleum stream substances
Reaction products of 1,3,4-thiadiazolidine-2,
5-dithione, formaldehyde and 4-heptylphenol,
branched and linear (RP-HP)
[with ≥0.1% w/w 4-heptylphenol, branched and linear]
ED (environment)
  • Corrosion inhibitors in lubricant additives,
    lubricants and greases
Tricobalt tetraoxide containing
≥ 0.1% w/w nickel oxides
Carc. 1A
  • Used in laboratory chemicals, pH regulators and in water treatment products, semiconductors, polymers and coatingproducts
  • Manufacture of pigments and for decoloring


Carc. 1A: Carcinogenicity category 1A

Carc. 1B: Carcinogenicity category 1B

CMR: Carcinogenic, mutagenic, and toxic for reproduction

ED: Endocrine disrupting properties

Muta. 1B: Germ cell mutagenicity category 1B

PBT: Persistent, bioaccumulative and toxic

STOT RE 1: Specific target organ toxicity after repeated exposure

UVCBs: Substance of unknown or variable composition, complex reaction products or biological materials

vPvB: Very persistent and very bioaccumulative


Comments and further information on use, exposure, alternatives and risks of the substances shall be submitted by October 20, 2017. 

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 or visit

For enquiries, please contact:

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

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