The European Chemical Agency (ECHA) continues with its efforts to tighten restrictions on using Substances of Very High Concern (SVHC). The ECHA officially recommended on December 20, 2011 a further 13 SVHC as candidates for the Authorization List (Annex XIV) of the REACH Regulation (EC No. 1907/2006) to the European Commission. This third set of recommendations could expand Annex XIV to 27 substances now classified as SVHC.
Chemicals listed in Annex XIV are marked with a sunset date (phase-out date) based on a number of month from its inclusion in Annex XIV, which varies by chemical from 36 to 42 months. The new recommended chemicals include: trichloroethylene, chromium trioxide, the acids derived from chromium trioxide and their oligomers, sodium chromate and dichromate, ammonium dichromate, potassium chromate and dichromate, cobalt dichloride, cobalt (II) sulfate, carbonate, dinitrate and diacetate. For further details about the chemical catalog numbers, refer to the reference list.
All manufacturers, importers and downstream users in the supply-chain have to apply for authorization with ECHA (http://echa.europa.eu/web/guest/about-us) to sell or make use of these substances in the European Union (EU). The applicant must submit a chemical safety report, which covers the risks of the particular substance to be considered for the scheme, as well as an analysis of possible alternative substances or technologies, which include present and future research and development processes.
Regardless of the quantity involved, if the substances included in the Authorization List are present on their own, as part of a mixture or are incorporated into an article, it should not be placed on the market or used after the sunset date, unless:
- A special authorization has been granted.
- The substance is exempted from the authorization requirement based on article 56 of REACH or based on special exemption indicated in Annex XIV.
- An application for authorization was made prior to the 'latest application date' but decision on the application for authorization has not yet been taken.
The incorporation of a substance into an article applies to any EU manufacturer who uses the substance in the manufacturing process. Imported finished articles are not subject to authorization. However, the product category may still be subject to authorization if it contains substances included in Annex XIV.
If you are thinking of applying for authorization or you would like to replace hazardous substances in your products by voluntary company policy, SGS technical experts can offer you several forms of assistance:
- Suggestions for possible safer alternative materials,
- Identification of substances classified as SVHC (http://www.sustainability.sgs.com/en/Facilities-and-Production/Product-and-Packaging/REACH/SVHC-Testing.aspx) in products,
- Advice on product design aspects,
- Consulting services to develop your case in an application for authorization for the use of a specific substance (providing an adequate control route and a socio-economic assessment).
About SGS REACH Services
SGS has the expertise to enable you to fully understand how REACH (http://www.sustainability.sgs.com/en/Facilities-and-Production/Product-and-Packaging/REACH.aspx) affects your company. By helping you manage REACH as part of your structure for general business compliance, SGS can put you securely in control of your obligations under REACH in the most cost effective and efficient way. SGS services range from consultancy and training to the hands-on implementation of REACH duties, which includes supply chain communications, due diligence and analytical testing.
Please contact us if you need further information.
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