Substances of Very High Concern - Updated

Written by Tanya | 12. February 2021

Read our updated blog post about the REACH candidate list of substances of high concern.

What is the Candidate List of Substances of High Concern?

The Candidate List is a list of substances which are considered to cause harm to people or the environment. Substances are added to the Candidate list for the following reasons:

Substances meeting the criteria for classification as carcinogenic, mutagenic, or toxic for reproduction (CMR) category 1A or 1B in accordance with the CLP Regulation.
Substances which are persistent, bioaccumulative and toxic (PBT) or very persistent and very bioaccumulative (vPvB) according to REACH Annex XIII.
Substances on a case-by-case basis, that cause an equivalent level of concern as CMR or PBT/vPvB substances e.g. endocrine disruptors.

Download our guide to the 22 substances you should replace now

The Candidate List was updated in Jan 2021 to include two new substances. The list now contains a total of 211 chemicals which are considered to cause significant harm to people, or the environment based on the criteria listed above.

Source: ECHA

Once a chemical has been added to the Authorisation list there is a possibility that these will be included on the Authorisation List in the future. This would mean that a company must apply for permission in order to continue to use the chemical.

It is important to continue to monitor the Candidate and Authorisation lists in relation to your chemical inventory to determine what your obligations will be.

Download our guide to the 10 most common dangerous substances

How does this affect you?

When a substance is added to the Substance of Very High Concern list you may have some immediate obligations you will have to fulfil. It is important to take into account substances, mixtures, and articles in your organisation as you may have obligations if any of these contain SVHCs.

Substances in Articles

You may have a number of obligations if you supply or import articles which contain substances or very high concern.

If your article contains above 0.1% w/w of a substance on the Candidate list, you must provide information downstream to the user on the safe use of the article. This must be provided within 45 days of the request being submitted.
Since January 2021 there is a requirement to notify under the Water Framework Directive (SCIP) substances on the candidate list present in articles at a concentration above 0.1%.
There is an additional requirement to notify ECHA under the REACH regulation if you import or produce an article which contains substances of very high concern in concentrations of 0.1% w/w per article and if you import more than one tonne per year. There are some exemptions to this requirement depending on the exposure to humans and the environment.

Safety Data Sheets for Substances and Mixtures

If you supply substances which are present on the Candidate list, you must provide a SDS to your customers.

If you supply a mixture which contains a substance on the list and is present in a concentration ≥0.1% w/w then you will have to provide an SDS.

You must also update your SDSs if substances are added to the list during the biannual updates then you will have to update your SDSs to reflect this information.

Read: Regulations for Safety Data Sheets

View full post