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On December 17, 2015, the European Chemical Agency (ECHA) added five new Substances of Very High Concern (SVHC) to the Candidate List for Authorization. The new substances added are:
- 2,4-di-tert-butyl-6-(5-chlorobenzotrizol-2-yl)phenol (UV-327)
- 2-(2H-benzotriazol-2-yl)-4-(tert-butyl)-6-(sec-butyl)phenol (UV-350)
- Perfluorononan-1-oic-acid and its sodium and ammonium salts
These additions may impact your company if your company produces the following:
- chemicals and/or use processing aids
- UV-protection agents in coatings, plastics, rubber and cosmetics
- products that uses lithium ion batteries
- fluoropolymers, fire extinguishers, cleaning agents, textiles, polishing and waterproofing agents as well as liquid crystal display panels
If you fall into 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 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.