On March 13, 2019, European Chemical Agency (ECHA) opened its first public consultation of 2019 on three potential Substances of Very High Concern (SVHCs)[1].

SAFEGUARDS | Consumer Product NO. 038/19

Paint on brushes

The Candidate List will expand to 200 if these proposals are accepted. Interested parties have until April 29, 2019 to submit comments and further information on the use, exposure, alternatives and risks of these substances to ECHA.

The Three Potential SVHC Proposals

The first SVHC consultation of 2019 includes three proposals, one of which is 2,3,3,3-tetrafluoro-2-(heptafluoropropoxy) propanoic acid, its salts and its acyl halides. It belongs to the group of perfluorinated substances (PFAS) and is considered an SVHC because of its probable serious effects to the environment and human health. This substance is very persistent and very mobile in the aquatic environment in the form of 2,3,3,3-tetrafluoro-2-(heptafluoropropoxy)propanoate, which gives rise to an equivalent level of concern to other SVHCs. Its ammonium salt is used as a processing aid for the production of fluoro-polymers.

The second SVHC proposal is 2-methoxyethyl acetate, for its toxicity for reproduction, which may damage fertility and the unborn child. It will be the fifth glycol ether on the candidate list if its proposal is accepted. It is used as a solvent for gums, resins, waxes, and oils and in the manufacture of semiconductors, textile printing and photographic films.

The remaining substance, tris(4-nonylphenyl, branched and linear) phosphite (TNPP), is a UVCB and is identified as an SVHC candidate for containing 0.1% w/w 4-nonylphenol, branched and linear as endocrine disruptors for the environment. TNPP is primarily used as a stabilizer in rubbers and plastic products, as well as a binding agent in paints and coatings or adhesives.

The potential uses of these potential SVHCs are summarized in Table 1.

Table 1. Possible uses of the potential SVHCs in the Consultation List published by ECHA on March 13, 2019

No. Substance CAS No. / EC No. Classification Potential uses
1 2,3,3,3-tetrafluoro-2-(heptafluoropropoxy)propanoic acid, its salts and its acyl halides (covering any of their individual isomers and combinations thereof) - / - EQC Its ammonium salt is used as processing aid for the production of fluoro-polymers
2 2-methoxyethyl acetate 110-49-6 / 203-772-9 Repr. 1B Used as a solvent for gums, resins, waxes, and oils and in the manufacture of semiconductors, textile printing and photographic films
3 Tris(4-nonylphenyl, branched and linear) phosphite (TNPP) with ≥ 0.1% w/w of 4-nonylphenol, branched and linear (4-NP) - / - EQC
  • Used as a stabilizer in rubbers and plastic products
  • Manufacture of coating and adhesives


EQC: Equivalent level of concern
Repr. 1B: Toxic for reproduction category 1B
UVCBs: Substance of unknown or variable composition, complex reaction products or biological materials

Next Step:

Comments and further information on use, exposure, alternatives and risks of the substances shall be submitted by April 29, 2019.

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