SVHC Expansion & the Impacts on your Supply Chain

On 16 July 2019, the European Chemical Agency (ECHA) added four new Substances of Very High Concern (SVHC) to the REACH Candidate List for Authorization. This brings the list to 201 SVHC substances.  The 4 new substances added are:

• 2-methoxyethyl acetate (CAS RN 110-49-6; EC No. 203-772-9) Reason for inclusion: Toxic for reproduction (Article 57 (c)).  Uses are not registered under REACH.
• Tris(4-nonylphenyl, branched and linear) phosphite (TNPP) with ≥ 0.1% w/w of 4-nonylphenol, branched and linear (4-NP) (CAS RN Not given; EC No. Not given). Reason for inclusion: Endocrine disrupting properties (Article 57(f) – environment) Primarily used as an antioxidant to stabilize polymers.
• 2,3,3,3-tetrafluoro-2-(heptafluoropropoxy)propionic acid, its salts and its acyl halides (covering any of their individual isomers and combinations thereof) (CAS RN Not given; EC No. Not given). Reason for inclusion Equivalent level of concern having probable serious effects to the environment (Article 57(f) - environment); Equivalent level of concern having probable serious effects to human health (Article 57(f) – human health) Uses: Processing aid in the production of fluorinated polymers.
• 4-tert-butylphenol (PTBP) (CAS RN 98-54-4; EC No. 202-679-0). Reason for inclusion Endocrine disrupting properties (Article 57(f) – environment); Uses: Used in coating products, polymers, adhesives, sealants and for the synthesis of other substances.

This addition may impact your company if your company produces or is involved with the manufacturer or is a downstream user of any of the following:

• Adhesives
• Antioxidants
• Coated products
• Polymers
• Processing Aid
• Sealants
• Synthesis of other products

If you fall into any of these categories, you may need to revisit your compliance obligations. A successful approach to compliance requires data, systems, expertise and an executable process that starts with Verisk 3E’s “3 I’s”:

• Identification- Do you currently use these substances on their own, or as part of mixtures or articles?
• Impact Analysis – Complying depends on the use of the substance as it relates to concentration, annual import/export quantities, current registered uses, and exposure exclusions. 
• Information Collection and Distribution – Make sure you can provide documentation and information up and down your supply chain. Consumers are entitled to complimentary information within 45 days of their original request, and ECHA must be conditionally notified no later than 6 months after a substance is listed.  

If interpreting, managing and executing on these requirements is burdensome, Verisk 3E can help. To receive technical information on the recent SVHC additions, explore best practices and discover how Verisk 3E can support supply chain material compliance, click here.