REACH SVHC UPDATE – REACH 181

On January 15, 2018, ECHA added seven new substances of very high concern (SVHC) to the REACH candidate list. The SVHC list is now at 181 substances. The new SVHC and common usage is found in the table below.

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As REACH continues to update and evolve, it is very important to have the ability to determine individual component compliance in a real-time environment with access to the latest compliance information from your suppliers. Of similar importance is the ability to have a direct communication link to the contacts at your suppliers who author and provide the compliance data that you need. Green Data Exchange provides this today.

Please continue to check the Q Point Technology Blog for recent news on regulatory changes, including REACH updates.

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REACH SVHC UPDATE – REACH 174

On July 7, 2017, ECHA added one new substances of very high concern (SVHC) to the REACH candidate list. The SVHC list is now at 174 substances. The new SVHC and common usage is found in the table below.

 

SVHC

CAS No.

Reason for Inclusion

Where Used

Perfluorohexane-1-sulphonic acid and its salts   355-46-4 (for the acid)

 

No specific CAS for the salts of the acid

 

vPvB (very persistent and very bioaccumulative) ·      Formerly used in firefighting foam and carpet treatment

·      Stain and water repellent

·      Some R&D applications as a process chemical

·      Paper and packaging

·      Non-stick cookware

As REACH continues to update and evolve, it is very important to have the ability to determine individual component compliance in a real-time environment with access to the latest compliance information from your suppliers. Of similar importance is the ability to have a direct communication link to the contacts at your suppliers who author and provide the compliance data that you need. Green Data Exchange provides this today.

Please continue to check the Q Point Technology Blog for recent news on regulatory changes, including REACH updates.

REACH SVHC UPDATE – REACH 173

On January 12, 2017, ECHA added four new substances of very high concern (SVHC) to the REACH candidate list. The SVHC list is now at 173 substances. The new SVHC and common usage is found in the table below.

SVHC CAS No. Reason for Inclusion Where Used
4,4′-isopropylidenediphenol     80-05-7 Toxic for reproduction Polymers and in manufacture of plastic products
4-Heptylphenol, branched and linear  

 

 

Equivalent level of concern having probable serious effects to environment Not registered in EU – uses in R&D

Derivatives may include greases and lubricants

Nonadecafluorodecanoic acid (PFDA) and its sodium and ammonium salts

Nonadecafluorodecanoic acid

 

·      Ammonium nonadecafluorodecanoate

·      Decanoic acid, nonadecafluoro-, sodium salt

 

    335-76-2

  • 3108-42-7
  • 3830-45-3
Toxic for reproduction

 

PBT (persistent, bioaccumulative, & toxic)

Textiles, packaging, firefighting foam
p-(1,1-dimethylpropyl)phenol     80-46-6 Equivalent level of concern having probable serious effects to environment Resins and lacquers, germicide in cleaning solutions, adhesives, paints, some rubber curing uses for a derivative

REACH SVHC UPDATE – REACH 169

On June 20, 2016, ECHA added one new substances of very high concern (SVHC) to the REACH candidate list. The SVHC list is now at 169 substances. The new SVHC and common usage is found in the table below.

SVHC CAS No. Reason for Inclusion Where Used
Benzon[def]chrysene

(Benzo[a]pyrene)

 

50-32-8

Toxic for Reproduction

Carcinogenic

Mutagenic

PBT (persistent, bioaccumualtive, & toxic)

vPvB (very persistent & very bioaccumulative)

 

Coal tar, residential wood burning, fuel exhaust, could be formed in manufacturing including asphalt production.

Regulatory Roundup – 2015

In an effort to keep you informed of the latest regulatory changes affecting material content compliance programs, the following is a review of the major regulatory developments from the past year.

RoHS

In June, the EU commission amended RoHS with Directive (EU) 2015/863. This adds four new substances, all phthalates, to the Restricted Substances list as found in Annex II of the RoHS Directive (2011/65/EU).

The new substances and common usage are found in the table below.

Substance CAS No. Where Used
Bis(2-Ethylhexyl) phthalate (DEHP) 117-81-7 Plasticizer (PVC products), hydraulic fluid, dielectric fluid in capacitors.
Benzyl butyl phthalate (BBP) 85-68-7 Plasticizer (vinyl foams)
Dibutyl phthalate (DBP) 84-74-2 Plasticizer, cosmetic additive, used in printing inks and adhesives, ectoparasiticide
Diisobutyl phthalate (DIBP) 84-69-5 Plasticizer (nitro cellulose plastic), lacquer manufacture, methyl methacrylate applications

 

Restriction of the new substances comes into force on July 22, 2019. Category 8 & 9 products (medical devices & monitoring and control devices) are given an additional two years to comply and will be enforced on July 22, 2021.

RoHS exemptions are set to expire on July 21, 2016. Guidance from the EU had been expected prior to 2016. Nothing has been published, yet. Please continue to monitor the Q Point blog for further updates.

 

REACH

On December 17, 2015, ECHA added five new substances of very high concern (SVHC) to the REACH candidate list. The SVHC list is now at 168 substances. The new SVHC and common usage are found in the table below.

SVHC CAS No. Reason for Inclusion Where Used
Nitrobenzene

 

98-95-3 Toxic for reproduction Manufacture of other substances (aniline)
2,4-di-tert-butyl-6-(5-chlorobenzotriazol-2-yl)phenol (UV-327) 3864-99-1 Very persistent and very bioaccumulative (vPvB) UV-protection agents in coatings, rubber, plastics, and cosmetics
2-(2H-benzotriazol-2-yl)-4-(tert-butyl)-6-(sec-butyl)phenol (UV-350) 36437-37-3 vPvB UV-protection agents in coatings, rubber, plastics, and cosmetics
1,3-propanesultone

 

1120-71-4 Carcinogenic Lithium ion batteries – electrolyte fluid
Perfluorononan-1-oic-acid and its sodium and ammonium salts 375-95-1

21049-39-8

4149-60-4

Toxic for reproduction

 

Persistent, bioaccumulative, and toxic (PBT)

Processing aid for fluoropolymer manufacture, lubricating oil additive for fire extinguishers, cleaning agent, textile antifouling finishing agent, polishing surfactant, waterproofing agents and in liquid crystal display panels.

 

On September 10, 2015, the Court of Justice of the European Union (EU Court of Justice) ruled on the interpretation of an “article” per the previous interpretation of REACH. In their ruling, the EU Court of Justice indicates “there is no need to draw a distinction between the situation of articles incorporated as a component of a complex product and that of articles present in an isolated manner.”

The court also ruled “that each of the articles incorporated as a component of a complex product is covered by the relevant duties to notify and provide information when they contain a substance of very high concern in a concentration above 0.1% of their mass” The European Chemicals Agency (ECHA), the regulatory authority of REACH, has adopted this ruling by the EU Court of Justice.

On December 17, 2015, ECHA updated its “guidance on requirements for substances in articles.” This update removes reference to the 0.1% SVHC limit that is no longer consistent with the ruling by the EU Court of Justice. ECHA further declares that a comprehensive update to the guidance will follow in 2016. Please continue to monitor the Q Point blog for further updates.

 

Conflict Minerals

The Conflict Free Sourcing Initiative (CFSI) has updated the Conflict Minerals Reporting Template (CMRT) to version 4.01b. This replaces version 4.01(a) with a current smelter list. All versions of CMRT version 4 are still considered acceptable for the 2015 Reasonable Country of Origin Inquiry (RCOI).

On December 11, 2015, the SEC has issued proposed Resource Extraction Payment rules. Comments are due by January 25, 2016. These proposed rules apply to commercial entities issuing payments to foreign governments for resource extraction that (a.) are required to file annual reports under the Securities Exchange Act, and (b.) engage in the commercial development of oil, natural gas, or minerals.

On August 18, 2015, while upholding the majority of the regulation, a US federal appeals court maintained that public US companies do not need to disclose whether products contain 3TG from conflict sources. Requirements for RCOI and submission of the SEC Form SD are upheld. An independent private sector audit (IPSA) is no longer required unless a company’s filing indicates any part or product to be “DRC conflict free.”

Using GDX to Address Expected Changes in REACH Declaration

A recent change to the REACH Directive states that “articles incorporated as a component of a complex product [are] covered by the relevant duties to notify and provide information.” This means that the REACH compliance of a finished good will be affected by the REACH compliance of individual components within the finished good. In a sense, all components with a specific form and function are now considered articles and are held to REACH compliance reporting requirements. Green Data Exchange is already able to support the expected changes to the REACH reporting requirements.

The GDX Product Compliance feature allows users to view a bill of materials (BOM) and instantly determine compliance. With GDX, you can view REACH Compliance at the individual component level as well as the BOM/product level.

Screen Shot 2015-10-21 at 12.27.27 PMShown is a sample of the Product Compliance view in GDX. Note that each article incorporated in the product is expressed with its own compliance. This roll-up allows for easy identification of overall product compliance as well as easy identification of parts with out-of-date compliance and even parts affected by non-compliance. The ability to “notify and provide information” on the REACH compliance of individual components, sub-assemblies, and finished goods is addressed in Product Compliance view, thus addressing the changes in the latest REACH interpretation.

From the Product Compliance view, you can determine the status of all sourced components in a single click and even request data from your supplier in that view.

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Review all sourced components used in an internal part number. This allows for the ability to determine the responsiveness and quality of data received from one supplier to the next for your part. This can be used to inform sourcing decisions and to identify specific parts for removal from sourcing.

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As REACH continues to update and evolve, it is very important to have the ability to determine individual component compliance in a real-time environment with access to the latest compliance information from your suppliers. Of similar importance is the ability to have a direct communication link to the contacts at your suppliers who author and provide the compliance data that you need. Green Data Exchange provides this today.

European Union Court of Justice Rules on Definition of Article under REACH

On September 10, 2015, the European Union (EU) Court of Justice issued a preliminary ruling on the definition of articles including components with a specific form and function that are utilized in a larger assembly. Previously, the larger assembly being imported was held to the 0.1% concentration threshold for compliance based upon the weight of a Substance of Very High Concern (SVHC) in the imported good. Based upon the recent ruling “there is no need to draw a distinction between the situation of articles incorporated as a component of a complex product and that of articles present in an isolated manner.”

The Court “rules that each of the articles incorporated as a component of a complex product is covered by the relevant duties to notify and provide information when they contain a substance of very high concern in a concentration above 0.1% of their mass.”

While this is a preliminary ruling, it is expected to be finalized. However, there is not yet a timeline on this. ECHA is preparing guidance on how reporting REACH compliance is changed and affected.

Q Point Technology is tracking the changes in this regulation, along with all other relevant details in environmental material content compliance reporting. Please continue to follow our blog for the latest news and expert advice on how to address these regulatory changes effectively.