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November 10, 2008

REACH Update : Substances of Very High Concern (SVHCs). November 10, 2008. Presented by: A.J. Guikema Tetra Tech. Agenda. REACH registration will rarely apply to apparel/footwear SVHCs Communication of SVHCs in articles Other Substance issues.

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November 10, 2008

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  1. REACH Update : Substances of Very High Concern (SVHCs) November 10, 2008 Presented by: A.J. GuikemaTetra Tech

  2. Agenda • REACH registration will rarely apply to apparel/footwear • SVHCs • Communication of SVHCs in articles • Other Substance issues

  3. 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

  4. SVHCs • Substances of Very High Concern • 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….

  5. 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

  6. SVHCs

  7. 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 Ref: Article 33.1-2 of the REACH Regulation 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. To ensure suppliers are meeting REACH obligations, may be useful to get full disclosure

  8. 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 (1st 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

  9. 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

  10. Communication of SVHCs in Articles CONTENT TO BE COMMUNICATED -- Example from RIP 3.8

  11. Communication of SVHCs in Articles • Format for communications • Website • Explicit labeling (not on inside of package) • Label has URL - retailer downloads from web

  12. 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

  13. 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?

  14. 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?

  15. A.J. Guikema, Tetra Tech 734.213.4095 reach@tetratech.com Questions?

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