For European Union (EU) manufacturers and importers, complying with REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) is required to keep products on the market. The European Chemicals Agency (ECHA) regularly adds substances that may be restricted to its Candidate List. The most recent update on January 17, 2022, added four new Substances of Very High Concern (SVHC) to this list.
If you are required to comply with REACH, identifying these substances in your products and reporting the necessary chemical data to your customers is essential to keeping your products on the EU market. You now must go a step further and report these same SVHCs into the Substances of Concern in Products (SCIP) database, which can be viewed publicly.
New REACH SVHCs
6,6’-di-tert-butyl-2,2’-methylenedi-p-cresol (DBMC)
This is used in rubbers, plastics, and sealants and has been added to the Candidate List because it is toxic for reproduction.
S-(tricyclo(5.2.1.0’2,6)deca-3-en-8(or 9)-yl O-(isopropyl or isobutyl or 2-ethylhexyl) O-(isopropyl or isobutyl or 2-ethylhexyl) phosphorodithioate (DPM)
This is used in greases and lubricants and is included because it is persistent, bioaccumulative, and toxic (PBT).
tris(2-methoxyethoxy)vinylsilane
This can be found in rubber, lubricants, adhesives, inks, and fuels and is included because it is toxic for reproduction.
(±)-1,7,7-trimethyl-3-[(4-methylphenyl)methylene]bicyclo[2.2.1]heptan-2-one covering any of the individual isomers and/or combinations thereof (4-MBC)
This substance is found in cosmetics and is included because of its endocrine disrupting properties.
Your REACH Compliance
The first step to remaining compliant with REACH is to survey your supply chain and identify any of the new Candidate List substances in the products you purchase from your suppliers.
If any of the SVHCs on the Candidate List are present in your products (or in the components within those products) at or over the 0.1% threshold, you will need to communicate with your customers concerning its presence and provide safe use instructions. You will also need to continue to make sure your imported and manufactured substances and mixtures are registered with REACH if they exceed one metric ton per year.
Get REACH Support
Remaining compliant with REACH is critical to maintaining your access to EU and UK markets. For support in identifying Candidate List SVHCs in your products, reporting data, or communicating effectively with your suppliers, contact Tetra Tech’s REACH experts today at [email protected]. Our team has been working with REACH regulations for years and can help you easily understand and meet your reporting obligations.
