What you should do now: Eight new substances have been added to the REACH candidate list

REACH

As of 8 July 2021, there are 219 chemical substances and groups of substances on the REACH Candidate List. This includes the following eight new substances:

  • 2-(4-tert-butylbenzyl)propionaldehyde and its individual stereoisomers
  • Orthoboric acid, sodium salt
  • 2,2-bis(bromomethyl)propane1,3-diol (BMP); 2,2-dimethylpropan-1-ol, tribromo derivative/3-bromo-2,2-bis(bromomethyl)-1-propanol (TBNPA); 2,3-dibromo-1-propanol (2,3-DBPA)
  • Glutaral
  • Medium-chain chlorinated paraffins (MCCP) UVCB substances consisting of more than or equal to 80% linear chloroalkanes with carbon chain lengths within the range from C14 to C17
  • Phenol, alkylation products (mainly in para position) with C12-rich branched alkyl chains from oligomerisation, covering any individual isomers and/ or combinations thereof (PDDP)
  • 1,4-dioxane
  • 4,4′-(1-methylpropylidene)bisphenol

According to the ECHA, most of these substances have been added to the Candidate List because they are hazardous to human health as they are toxic to reproduction, carcinogenic, respiratory sensitizers, or endocrine disruptors. Some of the newly added substances are used in consumer products such as cosmetics, scented articles, rubber, and textiles. Others are used as solvents, flame retardants or to manufacture plastics products.

Impact on companies

Any suppliers of articles containing a Candidate List substance in a concentration higher than 0.1% by weight must provide their customers with information on their safe use. Consumers must also be provided with this information if they request it.

Importers and producers of articles containing a Candidate List substance must report them to the ECHA within six months from now. This is because the EU Waste Framework Directive specifies that the ECHA must be informed if any products contain substances of very high concern. The declaration is then sent to the SCIP database. From September 2021, the information in this database will eventually be published on the agency’s website (on the SCIP dissemination portal).  The purpose of this is to ensure waste management companies and consumers are aware of chemical substances that are contained in products.

It is also likely that these substances will be included in the Authorization List in the future, which means companies will need to apply for a permit if they wish to continue using them.

The next steps

So, what does this mean for you? All material data sheets/dossiers now have to be checked and, if necessary, modified in the IMDS, the CDX and the SCIP database.

This sounds like a challenging task, but don’t worry – we’re here to help!

We can research all the materials and record them in the IMDS and CDX systems. We can manage and maintain all the data and, if required, we can also create, modify and process material data sheets (MDS).

We can also help you manage any SCIP database requirements you may have. For example, we can provide an impact analysis (product portfolio analysis), check for SCIP compliance, prepare the data in IUCLID format, create, and validate SCIP notifications, and prepare SCIP dossiers which we then submit to ECHA.

We also work in partnership with the VDE Institute’s laboratory, which enables us to analyze your products and materials if this data is currently not available or incomplete.

If you prefer to manage all these tasks yourselves, we can help you acquire the necessary knowledge and expertise with our high-quality training courses:

  • Our “SCIP database” training courses (no. 6180 und no. 6181) give you a thorough grounding in the database’s legal framework (Waste Framework Directive) and provide you plenty of opportunities to practice using the database.
  • Our “Automating MDS updates” training course (no. 6116) teaches essential tips and tricks to help you automatically update all outdated product data in the IMDS.
  • Our “Current REACH requirements” course (no. 6194) enables you to learn all the latest information about REACH and the impact any changes have on your organization.
  • We also offer tailored in-house training courses for the CDX.