SVHC Expansion & the Impacts on your Supply Chain

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January 15, 2019 - Bernie Henn

On January 15, 2019, the European Chemical Agency (ECHA) added six new Substances of Very High Concern (SVHC) to the REACH Candidate List for Authorization. This brings the list to 197 SVHC substances.  The 6 new substances added are:

  • 2,2-bis(4'-hydroxyphenyl)-4-methylpentane (CAS RN 6807-17-6; EC No. 401-720-1). There are no active registrations under REACH. Toxic for reproduction.
  • Benzo[k]fluoranthene (CAS RN 207-08-9; EC No. 205-916-6). Not registered under REACH. Normally not produced intentionally but rather occurs as a constituent or impurity in other substances.  Carcinogenic, PBT and vPvB.
  • Fluoranthene (CAS RN 206-44-0 & 93951-69-0; EC No. 205-912-4). Not registered under REACH. Normally not produced intentionally but rather occurs as a constituent or impurity in other substances. PBT and vPvB.
  • Phenanthrene (CAS RN 85-01-8; EC No. 201-581-5). Not registered under REACH. Normally not produced intentionally but rather occurs as a constituent or impurity in other substances. vPvB.
  • Pyrene (CAS RN 129-00-0 & 1718-52-1; EC No. 204-927-3). Used as a transported Intermediate for the manufacture of fine chemicals.  PBT and vPvB.
  • 1,7,7-trimethyl-3-(phenylmethylene) bicyclo[2.2.1]heptan-2-one; also 3-benzylidene camphor; also 3-BC (CAS 15087-24-8; 239-139-9) Not yet registered under REACH. Endocrine disrupting properties - environment

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
  • Coal stream Very Complex and Variable/Partly Undefined Composition (UVCB) substances
  • Coated products
  • Coated products (non-metal)
  • Monomers
  • Petroleum stream Very Complex and Variable/Partly Undefined Composition (UVCB) substances
  • Polyaromatic Hydrocarbons (PAHs)
  • Polymers
  • Surfactants
  • Thermal Paper

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.

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