ECHA has submitted two notifications the to the TBT: G/TBT/N/EU/519,  and G/TBT/N/EU/520 aims at identifying TMA as a substance of very high concern due to its respiratory sensitisation properties according to Article 57(f) of Regulation (EC) No 1907/2006 (REACH) , DCHP as a substance of very high concern due to its classification as toxic to reproduction according to Article 57(c) of Regulation (EC) No 1907/2006 (REACH) and due to its endocrine disrupting properties whose effects to human health give rise to an equivalent level of concern according to Article 57(f) of that Regulation. DCHP and TMA  was respectively on the fifteenth and  sixteenth batch SVHCs public consultation  list.

Proposed date of adoption: March 2018

Proposed date of entry into force: March 2018

Final date for comments: 60 days from notification

Proposed Substances

No.Substance NameEC No.CAS No.UseReason for proposing
1benzene-1,2,4-tricarboxylic acid 1,2 anhydride (trimellitic anhydride, TMA)209-008-0552-30-7Manufacture chemicals, such as polyester resin, polyimide resin, high temperature insulation materials, PVC plasticizers, etc.Equivalent level of concern having probable serious effects to the environment (Article 57 f)
2Dicyclohexyl phthalate (DCHP)201-545-984-61-7Consumer Uses in 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 ; PVC, rubber , plastic  articles as plastisol.Toxic for reproduction (Article 57 c)
Equivalent level of concern having probable serious effects to human health and the environment (Article 57 f)

Legal Obligations of Companies

Producers and exporters of protucts containing any of the SVHC candidates shall notify ECHA if both of the following conditions apply:

i. the substance is present in those articles in quantities totaling over on tonne per producer or exporter per year, and

ii. the substance is present in those articles above a concentration of 0.1% weight by weight.

CTI Suggestion

As the SVHC Candidate List is consistently updated, companies are facing increasing numbers of control requirements. Producers of articles shall notify the ECHA within six months after a substance has been included in the SVHC Candidate List if they meet the conditions. Companies should focus on REACH news and take necessary preventative actions as soon as possible.