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Do you supply products into the EU/EEA? Do you know whether those products contain any Substances of Very High Concern?

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The European Chemicals Agency (ECHA) list of Substances of Very High Concern (SVHCs) was updated on 25 June 2020 to include additional substances including Butyl 4-hydroxybenzoate (Butylparaben). This is a timely reminder for EU/EEA suppliers of products (such as shoes, furniture, clothing etc.) of their obligations where a Substance of Very High Concern is present in any product above 0.1% weight by weight.

The 0.1% threshold applies to each component in a product, not the overall product. Take for example a shoe, each individual part is considered separately (e.g. the laces are considered separately from the sole) when applying the SVHC threshold test.

Where such a substance is present product suppliers (including retailers) have an obligation to provide consumers with sufficient information to allow safe use of that product including, as a minimum the name of that SVHC within 45 calendar days of a request. They also have to proactively provide professional users with sufficient information to allow safe use of that article, including the name of that substance.

In addition, from 5 January 2021 suppliers providing such products to professionals/distributors also have to submit information to ECHA’s Substances of Concern In articles as such or in complex objects (Products) Database (SCIP Database). Suppliers of articles will be able to submit information when the “production version” of the database is released, expected to be at the end of October 2020. The additional obligation to submit information to the SCIP Database (imposed under the revised Waste Framework Directive) is intended to support the circular economy. In particular by supporting the substitution of SVHCs, providing information relevant to waste separation and recycling to support waste operators in making sure that SVHCs are not incorporated in recycled materials in the future and allowing authorities to monitor the use of SVHCs and initiate appropriate actions relevant to the whole lifecycle of the article. It is also expected that the database will enable consumers to make more informed purchasing decisions.

ECHA has published the detailed information which needs to be submitted to the SCIP Database which includes:

  • information relevant to the identification of the article (product);
  • name, concentration range and location of the SVHC; and
  • other information on the safe use of the article, in particular if the above information is not sufficient to ensure the proper management of the article as waste

The industry will need to ensure that it has the required information in order to submit this to the SCIP Database in advance of the 5 January 2021 deadline. The SCIP Database does not apply to articles supplied directly and exclusively to consumers where there is no other distributor or other actor involved in the supply chain.

The list of Substances of Very High Concern is generally updated in June/July and in December/January so it is important to monitor the list to ensure that all relevant substances are identified. The list currently comprises 209 SVHCs.