ECHA Plans Database on Articles Containing Candidate List Substances

On July 11, 2018, ECHA announced plans for a new database for declaration of information related to articles containing Candidate List Substances. Declarations would be submitted by companies “producing, importing, or selling articles that contain Candidate List substances.”

For use by waste operators and consumers, this new database is being established in accordance with recent updates to 2008/98/EC, the Waste Framework Directive. Changes to the Waste Framework Directive passed on May 22, 2018 and set new targets for reuse and recycling of municipal waste. The database should “help waste operators in treating waste and recycling materials.”

Intention of the database is to help inform consumers to make safer choices, driving safe substitutes to market and “improve the risk management of chemicals during waste recovery” and “promote non-toxic material cycles.”

Current plans indicate the creation of the database by the end of 2019 with companies submitting data by the end of 2020. Note that if you are already using Q Point’s Green Data Exchange, you are already collecting the data and information that you would need to declare information on the use of SVHC in your articles.

Q Point will continue to follow developments on the new database and will post updates to this blog. For companies looking to collect data on Candidate List substances and usage within their own supply chain, please see our website for more details on Q Point’s solution, Green Data Exchange. For more information on the database, please see ECHA’s press release here or information on the Waste Framework Directive here.

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Lead in Glass and REACH 191

ECHA has added lead (CAS No.: 7439-92-1) to the REACH Candidate List of substances, as of 27 June 2018. However, the way in which lead is used in your products may exempt it from the notification requirement of REACH, particularly if the lead is used in an application of a glass or ceramic frit. This article examines RoHS exemption 7(c)-I, currently renewed through 21 July 2021, REACH Annex V and its guidance from November 2012, as well as recent statements and positions from glass and ceramic manufacturers.

RoHS exemption 7(c)-I states the application of lead in the following is exempted.

Electrical and electronic components containing lead in a glass or ceramic other than dielectric ceramic in capacitors, e.g. piezoelectronic devices, or in a glass or ceramic matrix compound.

Based upon this exemption, any manufacturer using lead in this application would cite the exemption 7(c)-I on an EU RoHS Declaration of Conformity. However, the application of lead in this scenario would not require notification to customers on the use of lead as an SVHC for REACH. To understand why this is the case, let’s look at REACH Annex V.

Annex V of the REACH Directive lists thirteen categories of substances for which registration of the substance with ECHA is not necessary. There are, however, conditions to be met in order to claim the exemption. Criteria for meeting the conditions vary by category. Per the guidance on Annex V, published in 2012, but cited by ECHA as recently as May 2018, the criteria for glass and ceramic frit is that it must not meet the criteria for classification as dangerous according to Regulation (EC) No 1272/2008 which replaced the fully repealed Directive 67/548/EEC and Directive 1999/45/EC.

The rationale for the exemption is based upon the characterization of glass as an UVCB substance (unknown or variable composition, complex reaction products or biological materials). The guidance also suggests that glass “can best be defined through its starting materials and production process” for the purposes of legislation. Furthermore, the raw materials used in manufacturing a particular glass “meet the definition of intermediates inasmuch as they are transformed by synthesis into…glass.” This is based upon EU Court case-law found here. To this end, any glass or ceramic frit that does not possess significant hazard properties is exempted from REACH substance registration, thus precluding it from evaluation and further actions under REACH including notification of its use in articles.

Recent positions reiterating the exemption of glass have been stated by glass manufacturers and their associations. Glass Alliance Europe has published information detailing this position as well as many citations supporting the position of no notification on the use of lead for 7(c)-I exempted use of lead. Per Glass Alliance Europe there is “no obligation to notify under Art. 7(2) of REACH, nor to communicate information down the supply chain under Art. 33 of REACH. This was confirmed in ECHA Q&A – ID 1218 – 12/09/2016 relating to boron compounds.” Further, a prominent glass supplier in Germany states that as their “products consist mainly of glass and glass, as a substance, is not included in the Candidate List, there are no information duties under [REACH].”

To stay up to date with ever-changing regulations, obtain the data you need, and communicate in a real-time environment with your suppliers and customers for compliance information, please consider Green Data Exchange. To learn more, visit the Q Point Technology website and follow our corporate blog for the latest in news relative to material content compliance.

REACH SVHC UPDATE – REACH 191

On June 27, 2018, ECHA added ten new substances of very high concern (SVHC) to the REACH candidate list. The SVHC list is now at 191 substances. The new SVHC and common usage is found in the table below.

SVHC CAS No. Reason for Inclusion Common Usage
Benzene-1,2,4-tricarboxylic acid 1,2 anhydride

trimellitic anhydride; TMA

552-30-7 Respiratory sensitizing properties A reactive chemical compound used in the esterification of alcohols.

 

Benzo[ghi]perylene

 

191-24-2 PBT

vPvB

 

Research substance used to make dyes, plastics, pesticides, explosives, pharmaceuticals, bile acids, cholesterols, and steroids.

 

Decamethylcyclopentasiloxane

D5

541-02-6 PBT

vPvB

 

Emollient used in cosmetics, including sunscreen and hair care products.

 

Dicyclohexyl phthalate

DCHP

 

84-61-7 Toxic for reproduction

 

Endocrine disrupting properties

 

Substance used for manufacturing adhesives and sealants, coating products, fillers, putties, plasters, modelling clay, finger paints, non-metal-surface treatment products, inks and toners, polishes and waxes, polymers and textile treatment products and dyes.

 

Disodium octaborate

 

12008-41-2 Toxic for reproduction

 

Insecticide
Dodecamethylcyclohexasiloxane

D6

540-97-6 PBT

vPvB

 

Substance used in washing & cleaning products, polishes and waxes, cosmetics and personal care products and pharmaceuticals.

 

Ethylenediamine

EDA

 

107-15-3 Respiratory sensitizing properties A substance used in the manufacture of fuel additives, bleach activators, chelating agents and corrosion inhibitors

 

Lead

 

7439-92-1 Toxic for reproduction Used in metal, especially copper alloys and stainless steels. Commonly found in paints, construction materials, flooring, leather products, and electrical & electronic equipment.

 

Octamethylcyclotetrasiloxane

D4

556-67-2 PBT

vPvB

 

Found in cosmetics and personal care products, washing & cleaning products and polishes and waxes.

 

Terphenyl, hydrogenated

 

61788-32-7 vPvB Heat transfer medium, can also be used as a plasticizer.

 

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 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.

Screen Shot 2018-01-17 at 5.16.31 PM

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 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.