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Substances of Very High Concern (SVHC) Expansion and the Impacts to Your Supply Chain

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June 29, 2020Bernie HennBlog

On 25 June 2020 the European Chemical Agency (ECHA) added four new Substances of Very High Concern (SVHC) to the REACH Candidate List for Authorization. Three reprotoxins and one endocrine disruptor was added. This brings the list to 209 SVHC substances. The four newly added substances are as follows: 

  1. 1-vinylimidazole (CAS 1072-63-5; EC 214-012-0) 
    • Toxic for reproduction (Article 57c)
    • Used in formulations and as a monomer in production of polymers
  2. 2-methylimidazole (CAS 693-98-1; EC 211-765-7)
    • Toxic for reproduction (Article 57c)
    • Used as a catalyst in production of coating products
  3. Dibutylbis(pentane-2,4-dionato-O,O')tin   (CAS 22673-19-4; EC 245-152-0)
    • Toxic for reproduction (Article 57c)
    • Used as a catalyst and as an additive in production of plastics
  4. Butyl 4-hydroxybenzoate (Butylparaben) (CAS 94-26-8; EC 202-318-7)
    • Endocrine disrupting properties - human health (Article 57(f) – human health) 
    • Used in Cosmetics, personal care products and pharmaceuticals

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:

  • Additives for Production of Plastics 
  • Catalysts
  • Coated products
  • Monomers
  • Polymers

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. 

Verisk 3E can help with interpreting, managing and executing on these requirements. Discover how Verisk 3E can support supply chain material compliance and receive technical information on the recent SVHC additions and explore best practices.