Posts Tagged ‘SVHC’

138 SVHC Now

There are now 138 Substances of Very High Concern under REACH with the addition of another set of 54 chemicals December 19, 2012.  Producers and importers of articles have 6 months to notify ECHA if articles contain more than 0..1% by weight and the use hasn’t already been registered.

Companies need to keep on top of new listings (about every 6 months) and be prepared to find out whether articles you make, sell or buy contain >0.1% adding to more than 1 metric tonne/yr.  You can also see what’s likely to come up by looking at the list of “intentions” to add to the Candidate list here.

Also track whether any of the chemicals reach the “Authorization” (14 so far) stage that will restrict use.

EHS Strategies, Inc. can help you with the implications for your company.

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REACH Ambitious SVHC Intentions

Whew!  Make that 54 more chemicals ECHA is looking to add to the Substances of Very High Concern (SVHC) here.  See if your favorite is on the list and comment if you want by October 18.

Phthalates, nonylphenols, a bunch of lead compounds, propylene oxide, TDA and more….

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REACH Intentions

For those of you who like to get ahead of official listings under REACH, ECHA has a posting of “intentions” to list new SVHC Candidates, proposed restrictions and classification and labeling harmonization proposals: http://echa.europa.eu/web/guest/addressing-chemicals-of-concern/registry-of-intentions

Also be aware that there’s also a push to really up the number of SVHC by the end of the year (to 136 from the current 84).

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REACH: Another 13 SVHC Candidates

The REACH Substances of Very High Concern (SVHC) Candidate List just keeps getting longer: 13 more added from the CMR (carcinogen, mutagen, reproductive toxin) category: check the top of the current SVHC Candidate List

Remember: listing triggers notice to ECHA for articles within 6 months (unless use already registered) and informing customers if >0.1%. obligations

EHS Strategies, Inc. can help.

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Another batch of “intentions” to list Substances of Very High Concern (SVHC) have been released:

Heptacosafluorotetradecanoic acid, Pentacosafluorotridecanoic acid, Henicosafluoroundecanoic acid, Tricosafluorododecanoic acid

Methoxy acetic acid

Cadmium, Cadmium sulphide, Cadmium oxide

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REACH Intentions

If you want an advance look at what ECHA will be considering for Substances of Very High Concern and for Authorizations and restrictions under REACH, check out this site.  Each of these chemicals will be offered for public comment before it gets officially listed, but checking this site will give you time to prepare a response.

EHS Strategies, Inc. can help you decide how to deal with these listings.

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REACH: SVHC in Articles

Controversy remains on the notification and communication requirements for Substances of Very High Concern (SVHC) in articles.  Do you calculate the >0.1% wt/wt SVHC  according to each component or for the finished article as placed on the market?  Several countries (AUSTRIA, BELGIUM, GERMANY, FRANCE, NORWAY, SWEDEN ) say it’s by component and tough luck on importers: “Once an Article – Always an Article.”  ECHA says it’s the entire article.  The court will have to decide. But no lawsuits yet.

Here’s Germany’s guidance on the matter: pdf

EHS Strategies, Inc.
can help you decide how to deal with these requirements.

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ECHA has added 20 more chemicals to the Substances of High Concern (SVHC) list: more lead, chromate and arsenic compounds, phenolphthalein, dichloromethylenedianiline, BCME, EDC, anisidine, technical MDA, refractory ceramics and more.
The full list of SVHC is here

For these newly listed chemicals European importers and manufacturers must inform their downstream industrial users and respond to customer inquiries about the presence of these SVHC.  In addition, the batch listed in June  2011 are now subject to notification to ECHA for articles with >0.1% of those chemicals (along with all the other chemicals previously listed) unless the use in the articles were registered under REACH in November 2010.  More information is available from ECHA here.

EHS Strategies, Inc.
can help you understand and deal with these requirements.



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REACH Article Notifications of SVHC

The list of Substances of Very High Concern (SVHC) that were added in June 2011 need to be notified to ECHA by Dec 20, if >0.1% and > 1 tonne, unless the use has already been registered under REACH.

Remember – ECHA adds to the list every six months (watch for more in December), triggering communication downstream right away and notification six months later.

In addition, ECHA has issued a useful new Q&A  In that document ECHA emphasizes that you shouldn’t assume the short use description in existing dossiers covers your use.  Check with your suppliers.


EHS Strategies, Inc. can help you determine what your obligations are and how to meet them.


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The issue of whether the Substances of Very High Concern (SVHC) in articles is triggered at >0.1% weight of chemical to weight of the entire article placed on the market or to any component of that article remains controversial according to discussions at the September 23, 2011 REACH workshop.  ECHA guidance is still holding with the entire article weight in the denominator, but acknowledges that some member countries are saying they will enforce the RoHS approach on each component part.  ECHA and The European Commission are looking at how to resolve this issue.

Odds are good that this one is going to the European Court of Justice.

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