Transcript Slide 1
REACH Update : Substances of Very High Concern (SVHCs)
November 10, 2008
Presented by: A.J. Guikema Tetra Tech
Agenda
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REACH registration will rarely apply to apparel/footwear SVHCs Communication of SVHCs in articles Other Substance issues
REACH registration will rarely apply to apparel or footwear
Doesn’t apply to articles… Textiles Clothing/Footwear Packaging ……except for intentional releases Lotions, fragrances …and for ensuring any EU suppliers register Pigments, adhesives, etc
SVHCs
S
ubstances of
V
ery
H
igh
C
oncern Also known as the Candidate List, is a list of substances for potential inclusion in REACH Annex XIV, which itself lists substances subject to authorization.
SVHCs are considered to be: carcinogenic, mutagenic, or toxic for reproduction (CMR); persistent, bioaccumulative and toxic (PBT); very persistent and very bioaccumulative (vPvB); and, endocrine disruptors Substances of equivalent concern….
SVHCs
• •
Will be listed in “waves” – approximately semiannually. First wave started June 30, 2008
Registry of intent –www.echa.eu website June 2008 Annex 15 list – June 30, 2008 • • Candidate list – October 28, 2008
Second “wave” has already been announced
Registry of intent –www.echa.eu website October 2008 •
Ultimately all these substances will be banned for use in the EU
Addition to Annex XIV (authorization) list will occur
SVHCs
Communication of SVHCs in Articles
For a substance in an article: if the article is imported or produced in the EU, • and the substance is a SVHC (substance of very high concern) • and the substance is present in a wt/wt concentration in the article at greater than 0.1% then the substance must be communicated to
recipients
and
consumers
Recommendation: Need to, at a minimum, know presence of all SVHC’s, and know amounts if above 0.1% per article.
For RoHS and for substance vulnerability matters, should know SVHC regardless of threshold.
Ref: Article 33.1-2 of the REACH Regulation
Communication of SVHCs in Articles
Communication to recipients The obligation to provide available information on substances of very high concern to the recipients of the articles applies as soon as a substance has been included on the candidate list for authorization (1 st list was Oct 28, 2008) This is to be done at the time of shipment immediately after the substances has been included on the candidate list
Ref: Article 33.1 of the REACH Regulation
Communication of SVHCs in Articles
Communication to any consumer who asks Clock starts ticking upon consumer request Request may be sent to ANY actor in the supply chain, including retailers Non-Governmental Organizations (NGOs) will drive much of the effort
Ref: Article 33.2 of the REACH Regulation
Communication of SVHCs in Articles
CONTENT TO BE COMMUNICATED -- Example from RIP 3.8
Communication of SVHCs in Articles
Format for communications • Website • Explicit labeling (not on inside of package) • Label has URL - retailer downloads from web
Communication (Notification) of SVHCs in Articles
For a substance in an article: • • • if the article is imported or produced in the EU, and the substance is a SVHC (substance of very high concern) and the substance is present in a wt/wt concentration in the article at greater than 0.1% and the substance amounts to greater than 1 metric ton per year • and exposure to humans or to the environment cannot be excluded then the substance must be notified to the EU Chemicals Agency.
Ref: Article 7.2 of the REACH Regulation
Other Substance issues
SIN (Substitute It Now) List –www.chemsec.org
Released Sep 17, 2008 Will grow also Currently 300 substances No force of law Brand image affected, NGOs campaign Incorporate into RSL?
Other Substance issues
SVHCs (Candidate List) and SIN List substances are both important to track RSL Status – Integrate into current process, i.e. format, content Keeping up to date real-time?
Not include in RSL if certain that substance is not in apparel or footwear?
Questions?
A.J. Guikema, Tetra Tech
734.213.4095