On Juny 25th 2020 the ECHA (European Chemicals Agency) announced the addition of the following substances to the SVHC list (SVHC = Substance of Very High Concern):
- Dibutylbis(pentane-2,4-dionato-O,O')tin (CAS# 22673-19-4)
- Butyl 4-hydroxybenzoate (CAS# 94-26-8)
- 2-Methylimidazole (CAS# 693-98-1)
- 1-Vinylimidazole (CAS# 1072-63-5)
If a substance is listed on the SVHC list, this does not have an immediate effect on its use. It simply means that it is then flagged for inclusion in Annex XIV of the REACH Regulation, which might result in a future ban of its use or an authorisation requirement.
However, classification as a SVHC does involves an obligation to provide information or disclose usage as per Article 33 of the REACH Regulation. Thus, buyers along the supply chain (B2B) must be informed if an SVHC amounts to more than 0.1 % w/w in an article and must be provided information about the safe handling of the article. Consumers (B2C) are entitled - upon request - to receive information (free of charge and within 45 days) about the presence of SVHC with more than 0.1 % w/w in consumer products.
Importers and producers of articles containing a SVHC substance above a concentration of 0.1% (w/w), and whose production exceeds an annual quantity of more than one ton (of SVHC substances) have to notify ECHA accordingly.
To fulfil these obligations, we recommend all companies, especially those who are sourcing outside the EU, but also those who are sourcing within the EU, to contact their suppliers. Make them aware of the new requirements and ask whether some of the new (or the already existing) SVHC are present in their products.
As of January 2021, companies will also need to notify ECHA’s SCIP database if their articles contain Candidate List substances.
If you have any further requests regarding REACH, the SVHC list or related obligations please contact our experts.