EU – ECHA Launches First SVHC Consultation in 2018 on Eight Proposals
On March 8, 2018, ECHA opened the first 2018 public consultation on eight potential SVHCs.
SAFEGUARDS | Consumer Products NO. 033/18
On March 8, 2018, European Chemical Agency (ECHA) opened the first 2018 public consultation on eight potential Substances of Very High Concern (SVHCs) .
If these proposals are accepted the Candidate List will expand to 189. Interested parties have until April 23, 2018 to submit comments and further information on use, exposure, alternatives and risks of the substances to ECHA.
The eight potential SVHC proposals
Eight proposals are published for comments in the 2018 first SVHC consultation list, among which three potential SVHCs are cyclic polydimethylsiloxanes - octamethylcyclotetrasiloxane, decamethylcyclopentasiloxane and dodecamethylcyclohexasiloxane (i.e. D4, D5 and D6 respectively), which are considered to have PBT and vPvB properties. These cyclic polydimethylsiloxanes have various applications including, but not limited to, silicone polymer production, in washing and cleaning products, cosmetics and personal care products, polishes and waxes. Recently, the EU published regulations on D4 and D5 in wash-off cosmetic products with a limit of 0.1% by weight and the restriction will be effective from February 1, 2020 .
One SVHC proposal is Benzo[ghi]perylene, which belongs to the family of polyaromatic hydrocarbons (PAHs) and is also considered for inclusion owing to its classification as having PBT and vPvB properties. It is not produced intentionally but occurs together with other PAHs as a constituent of coal and petroleum stream UVCB substances.
Terphenyl hydrogenated is another vPvB substance on the consultation list. It is a UVCB substance used in coatings, adhesives, sealants, heat transfer fluid and as an additive in plastic applications.
One proposed SVHC is a respiratory sensitizer ethylenediamine - which is used in epoxy, PU, adhesives, coatings and other polymers, as well as processing aid agents, scavenging agents in refinery streams and corrosion inhibitors.
The remaining two substances are lead and disodium octaborate, which are both classified as toxic for reproduction. Lead is mainly used in lead-acid batteries and in lead sheets used in the construction industry. Lead is also used as shots and bullets for ammunition and for alloying steel, in soldering alloys, cable sheathing and for the production of oxides, pigments, stabilizers and other lead compounds. Lead is strictly restricted in jewelry and accessible parts of articles under REACH Annex XVII. Meanwhile, there are two restriction proposals on regulating lead in shot for shooting in wetland and its compounds in PVC articles as stabilizers . Disodium octaborate has wide dispersive use in the manufacturing industry, the building sector, in refractory mixtures, as micronutrient fertilizers, and for indoor and outdoor facilities.
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 March 8, 2018
||CAS No./EC No.
||Not produced intentionally but occurs as a constituent or impurity in coal and petroleum stream substances
||Respiratory sensitizing properties
PBT: Persistent, bioaccumulative and toxic
PVA: Polyvinyl alcohol
Repr. 1A: Toxic for reproduction category 1A
Repr. 1B: Toxic for reproduction category 1B
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 April 23, 2018.
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 firstname.lastname@example.org or visit www.sgs.com/reach
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