SVHC Expansion and the Impacts on Your Supply Chain
On July 10, 2017, the European Chemical Agency (ECHA) added one new Substance of Very High Concern (SVHC) to the REACH Candidate List for Authorization and modified the existing list in the case of 5 existing SVHC. The new substance added is called:
- Perfluorohexane-1-sulfonic acid and its salts (PFHxS) added for being very persistent and bio-accumulative (vPvB) (Article 57e) used as a plasticizer, lubricant, surfactant, wetting agent, corrosion inhibitor and in fire-fighting foams.
5 previous added chemicals were additionally re-named for also having Endocrine disrupting properties (Article 57(f) – human health. Those chemicals are:
- BPA used in the manufacture of Polycarbonate, epoxy resins, an antioxidant for PVC and in thermal paper production
- BBP; DEHP and DBP all phthalates used in PVC
- DIBP used in coating products, fillers, putties, plasters, modeling clay and polymers
This addition may impact your company if your company produces or is involved with the manufacturer or downstream user of any of the following:
- plastic products
- Poly Vinyl Chloride polymer (PVC)
- epoxy resins and hardeners
- wetting agents and surfactants
- corrosion inhibitors
- fire fighting foams
- Antioxidants for PVC
- Thermal paper – cash register receipt tape
- Coated products
- Putties and plasters
- Modeling clay
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.