SVHC Expansion & the Impacts on Your Supply Chain

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July 13, 2015 - Kami Blake

On June 15, 2015, the European Chemical Agency (ECHA) added two new Substances of Very High Concern (SVHC) to the Candidate List for Authorization. The new substances added are: 

  • 1,2-benzenedicarboxylic acid, di-C6-10-alkyl esters; 1,2-benzenedicarboxylic acid, mixed decyl and hexyl and octyl diesters with ≥ 0.3% of dihexyl phthalate
  • 5-sec-butyl-2-(2,4-dimethylcyclohex-3-en-1-yl)-5-methyl-1,3-dioxane [1], 5-sec-butyl-2-(4,6-dimethylcyclohex-3-en-1-yl)-5-methyl-1,3-dioxane [2] [covering any of the individual isomers of [1] and [2] or any combination thereof] 

These additions may impact your company if: 

  • you are a company that produces products such as plasticizers and lubricants, including adhesives, coatings, cable compounding, polymer foils, PVC compounds and artist supplies (modeling clay and finger paints)
  • you are a company that manufactures personal care and household products such as fine fragrances, soaps and detergents

If you fall into either of these two 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 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, 3E can help. To receive technical information on the recent SVHC additions, explore best practices and discover how 3E can support supply chain material compliance, click here.