SAFEGUARDS | Consumer Products NO. 011/19
On January 15, 2019, European Chemical Agency (ECHA) updated the Candidate List by adding six new Substances of Very High Concern (SVHCs) . The addition of these new SVHCs brings the total number of entries to 197.
Obligations for article producers and importers
According to Article 33 of REACH, European Union (EU) and European Economic Area (EEA) manufacturers and importers of articles are required to provide information to allow the safe use of products by the recipients upon supply, and to consumers within 45 days upon request, when the concentration of the SVHC in an article exceeds 0.1% (w/w). For articles that contain an SVHC in which the concentration is above 0.1%, with the quantity over one tonne per year, a notification shall be submitted to ECHA by the manufacturers or the importers under Article 7 of REACH. The notification of SVHCs in an article must be made within six months of their inclusion on the List. The notification deadline for the six new SVHCs added to the Candidate List is July 15, 2019.
Six New SVHC Candidates
Four of the new SVHCs added are benzo[k]fluoranthene (BkFA), fluoranthene, phenanthrene and pyrene – which belong to the family of polyaromatic hydrocarbons (PAHs). These PAHs are not produced intentionally but occur together with other PAHs as constituents of coal and petroleum stream UVCB substances.
The fifth, 2,2-bis(4'-hydroxyphenyl)-4-methylpentane is structurally similar to bisphenol A (BPA) and therefore is considered as an alternative to BPA in the manufacture of thermal paper. It is mainly used in polymer manufacturing and its minor uses include surface coatings, inks and adhesives.
The remaining SVHC candidate is 3-benzylidene camphor and has been included because of its endocrine disrupting properties for probable serious effects to the environment. It was used as UV filter in cosmetics and sun screen products; however, its use in cosmetic products was prohibited in 2015 by Regulation (EU) No 2015/1298.
The potential uses of these potential SVHCs are summarized in Table 1.
|1||2,2-bis(4'-hydroxyphenyl)-4-methylpentane||6807-17-6/ 401-720-1||Repr. 1B||
|2||Benzo[k]fluoranthene||207-08-9/ 205-916-6||Carc. 1B, PBT, vPvB||
|3||Fluoranthene||206-44-0/ 205-912-4||PBT, vPvB||
|5||Pyrene||129-00-0/ 204-927-3||PBT, vPvB||
|6||1,7,7-trimethyl-3-(phenylmethylene)bicyclo[2.2.1]heptan-2-one (3-benzylidene camphor)||15087-24-8/ 239-139-9||EQC||
Table 1. Possible uses of the potential SVHCs in the Consultation List published by ECHA on January 15, 2019
Carc. 1B: Carcinogenic category 1B
EQC: Equivalent level of concern
PBT: Persistent, bioaccumulative and toxic
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
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 email@example.com or visit http://www.sgs.com/reach
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