2022

SVHC list expanded: Observe information duties

January 2022 | European Chemicals Agency (ECHA) | New substances added to SVHC

On January 17th 2022 the ECHA (European Chemicals Agency) announced the addition of the following substances to the SVHC list (SVHC = Substance of Very High Concern):

  1. 6,6'-di-tert-butyl-2,2'-methylenedi-p-cresol (CAS# 119-47-1)
  2. tris (2-methoxyethoxy)vinylsilane (CAS# 1067-53-4)
  3. (±)-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) (no CAS#)
  4. S-(tricyclo(5.2.1.02,6)deca-3-en-8(or 9)-yl O-(isopropyl or isobutyl or 2-ethylhexyl) O-(isopropyl or isobutyl or 2-ethylhexyl) phosphorodithioate (CAS# 255881-94-8)

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 authorization requirement. 

However, classification as a SVHC does involves an obligation to provide information or disclose usage 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 that all companies 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.

Since January 2021, companies also need to notify ECHA’s SCIP database if their articles contain Candidate List substances.

If you have any questions regarding REACH, the SVHC list or related obligations please .

Regulatory Assessments

2021

California Proposition 65 Notices for BPA Chemicals in Socks >

September 2021 | Center for Environmental Health (CEH) | Notices sent for socks from containing up to 19 times over the safe limit of Bisphenol A (BPA).

Supply Chain Act (Germany) >

June 2021 | German law | Corporate Due Diligence in Supply Chains

New Substances of Very High Concern to Observe >

July 8, 2021 | ECHA (European Chemicals Agency) | 8 substances added to the SVHC (Substance of Very High Concern) list.

New EU Toy Safety Standard >

April 2021 | EN 71-3:2019+A1:2021 | The European Committee for Standardization (CEN) | Standard for the migration of 19 elements to be adopted as national standards by October 2021.

Turkey's Communique on the inspection of some textile clothing and
leather products >

January 1, 2021 | 2021/18 | regulates the procedures and principles for inspecting specified products against relevant legislation in terms of human health, safety of life, property, the environment and consumer protection

New EU standards on Safety of Children’s Clothing with Small Attachments >

January 2021 | CEN/TS 17394-1:2021, EN 17394-2:2020, CEN/TS 17394-3:2021, CEN/TS 17394-4:2021 | The European Committee for Standardization (CEN) developed 1 new standard and 3 new technical specifications (TS)

SVHC List Expanded: Observe information duties

January 19, 2021 | European Chemicals Agency adds to Substance of Very High Concern List

Two additional substances:

  • Bis(2-(2-methoxyethoxy)ethyl)ether (CAS# 143-24-8)
  • Dioctyltin dilaurate, stannane, dioctyl-, bis(coco acyloxy) derivs., and any other stannane, dioctyl-, bis(fatty acyloxy) derivs. wherein C12 is the predominant carbon number of the fatty acyloxy moiety (various CAS#)

If a substance is listed on the SVHC list, this does not have an immediate effect on its use. It 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 involve 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 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 fulfill these obligations, we recommend all companies 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 questions regarding REACH, the SVHC list or related obligations please contact our experts.


2020

REACH regulation adds unspecified Diisocyantes >

August 7, 2020 | European Commission has amended Annex XVII to the REACH regulation by adding unspecified Diisocyantes as entry 74

AATCC Textile Face Covering Draft Guidance >

July 8, 2020 | American Association of Textile Chemists &
Colorists releases textile face covering draft guidance

New Standard AfPS GS 2019:01 PAK on PAHs

April 10, 2020 | German Product Safety Commission (AfPS) has revised the PAHs standard

Substance of Very High Concern list expanded

January 16, 2020 | The European Chemicals Agency (ECHA) added substances to the SVHC list

Observe information duties for the added SVHCs:

  • 2-benzyl-2-dimethylamino-4'-morpholinobutyrophenone (CAS# 119313-12-1)
  • 2-methyl-1-(4-methylthiophenyl)-2-morpholinopropan-1-one (CAS# 71868-10-5)
  • Diisohexyl phthalate (CAS# 71850-09-4)
  • Perfluorobutane sulfonic acid (PFBS) and its salts

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 authorization 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.

If you have any requests regarding REACH, the SVHC list or related obligations please contact our experts.


2019

The Green Button Certification - Germany >

September 9, 2019 | The German government created a certification/label for sustainable textiles.

ECHA expands Substance of Very High Concern list

July 16, 2019 | The European Chemicals Agency added substances to the SVHC list.

Requirement: notify your customers if these substances are are ≥0.1%

  • 1. 2-methoxyethyl acetate (CAS# 110-49-6)
  • 2. 4-tert-butylphenol (CAS# 98-54-4)
  • 3. tris(4-nonylphenyl, branched and linear) phosphite (TNPP) with ≥ 0.1% w/w of 4-nonylphenol, branched and linear (4-NP)
  • 4. 2,3,3,3-tetrafluoro-2-(heptafluoropropoxy) propionic acid, its salts and its acyl halides; covering any of their individual isomers and combinations thereof

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.

If you want to be on the safe side, you have the possibility to have your raw materials or finished products tested in our laboratories for the above-mentioned substances as well as for further SVHC, or other harmful substances.

If you have any further requests regarding REACH, the SVHC list or related obligations please contact our experts.

Contact
Ben Mead
Managing Director
Hohenstein Institute America