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Tools & Software REACh: 201 Substances of very high concern and lead identified in PVC

| Editor: Florian Richert

The candidate list REACh of the European Chemicals Agency grows by four more substances of very high concern (SVHC) to a total of 201 substances. Details on the new entries and the companies' immediate obligation to inform their customers can be found in this article.

REACh: 201 Substances of very high concern and lead in PVC identified
REACh: 201 Substances of very high concern and lead in PVC identified
(Source: gemeinfrei / Unsplash)

The four Substances of Very High Concern (SVHC) newly added to the REACh candidate lists are as follows:

  • 2-methoxyethylacetate - a substance toxic to reproduction that is used as an industrial solvent for resins, oils and various types of rubber, for example in paints and in semiconductor manufacturing.
  • TNPP or Tris (4-Nonylphenyl, branched and linear) - a phosphite with ≥ 0.1 mass percent 4-Nonylphenol, branched and linear (4-NP) with - endocrine-damaging properties. TNPP and Tris are used as antioxidants and stabilizers for various polymers. Nonylphenol splitting is possible.
  • 2,3,3,3-Tetrafluoro-2-(heptafluoropropoxy) propionic acid - its salts and acyl halides (including their individual isomers and combinations thereof) - are likely to have serious effects on the environment and human health. The substance is used as a processing aid in fluoropolymer production and as a substitute for perfluorooctanoic acid (PFOA).
  • 4-tert butylphenol has endocrine disrupting properties. The substance is used, for example, in the manufacture of polycarbonates, phenolic resins, epoxy resins, paints, adhesives and coatings.

Obligations for companies

The Fachverband der Bauelemente Distribution (FBDi) (Association of Construction Elements Distribution) draws the attention of companies to the fact that they are subject to immediate information obligations in connection with the substances listed in the candidate list: If articles contain more than 0.1 mass percent of an SVHC mentioned in the candidate list, companies within the EU must provide their commercial customers with sufficient information for the safe use of this article, but at least state the name of the substance contained (Art. 33 (1) of REACh Regulation (EC) No. 1907/2006). This information must be made available to consumers on request within 45 days.

Each individual component of a final product counts

Based on a ruling of the European Court of Justice in September 2015, the limit of 0.1% by mass also applies to products that have already become part of another product.
This means that a product is defined as every single component of a product and not just the end product.

Restriction of lead in PVC products

The EU wishes to restrict the use of lead and lead compounds in the manufacture of PVC products and the placing on the market of lead-containing PVC products and has published an amendment to Annex XVII of the REACh Regulation (entry 63). According to this, PVC products may no longer be placed on the market if the lead concentration ≥ is 0.1 mass percent of the PVC material. Exceptions exist, for example, for hard and soft PVC recycling material and for PVC silica separators in lead batteries. The transitional period is 24 months from the date of entry into force.

Annex XVII lists substances, groups of substances or mixtures together with the associated restriction conditions which, due to their health or environmental risks, may not be manufactured, placed on the market or used at all or only to a limited extent.

This article was previously published in German on the Elektronikpraxis.

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