SVHC Expansion & the Impacts on Your Supply Chain

On January 15, 2018, the European Chemical Agency (ECHA) added eight new Substances of Very High Concern (SVHC) to the REACH Candidate List for Authorization.

The new substances added are:

• Benz[a]anthracene
• Cadmium carbonate
• Cadmium hydroxide
• Cadmium nitrate
• Chrysene
• Dodecachloropentacyclo[12.2.1.16,9.02,13.05,10]octadeca-7,15-diene (Dechlorane Plus) [covering any of its individual isomers or any combination thereof].
• Reaction products of 1,3,4-thiadiazolidine-2,5-dithione, formaldehyde and 4-heptylphenol, branched and linear (RP-HP)

One previous added chemical was additionally re-named for also having an equivalent level of concern having probable serious effects to the environment (Article 57 f).  That chemicals is:

• 4,4’-isopropylidenediphenol (bisphenol A; BPA)

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

• Adhesives
• Antioxidants for PVC
• Binding agents
• Ceramic products
• Cosmetics
• Chemicals
• Coated products
• Electrical equipment
• Electronic equipment
• Epoxy resins and hardeners
• Glass
• Greases
• Have a constituent or impurity in your substance not registered under REACH
• Laboratory chemicals
• Lubricants
• Non-plasticizing flame retardant
• Optical equipment
• Personal care products
• Polymers
• Plastic products
• Polycarbonate
• Poly Vinyl Chloride polymer (PVC)
• Porcelain
• pH regulator
• Sealants
• Semiconductors
• Thermal paper – cash register receipt tape
• Water treatment 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.