About the PFAS update
I thought PFAS were already on the SIN List?
We have added a number of PFAS substances over the years. Before this update, there were in total 46 PFAS chemicals on the SIN List. We had added them after individual assessments for being either Persistent, Bioaccumulative and Toxic (PBT/vPvB) or Persistent, Mobile and Toxic (PMT/vPvB).
What is new is that we have added such a large group of PFAS chemicals. This time they have not been individually assessed. Instead, they have been added based on two criteria:
- They fulfil the OECD definition for being PFAS substances
- They have been registered for being produced and/or used in the EU or the US
Why have you not included all PFAS chemicals?
There are many different figures circulating regarding how many PFAS substances there are. It depends on what databases and definitions you use. One good source for investigating PFAS is PubChem PFAS tree. According to this, there are more than six million substances fulfilling the OECD definition.
However, many of these are only patents for substances that have never been produced other than at laboratory scale. There are also, for example, degradation products from other PFAS in this database.
The SIN List is meant to be a guiding tool for substitution and has always focused on listing the most relevant hazardous substances, rather than all of them. This means that there are problematic substances that are not on the SIN List. But the ones on the SIN List are there for a good reason. Not only do they fulfil the SVHC hazard criteria, they are also relevant on the market since they are produced and used.
Can you really prove that all of these substances are SVHCs?
The idea of placing PFAS as a group on the SIN List has come up repeatedly over the last few years. When placing a substance on the SIN List, we have always ensured that the substance fulfils the SVHC criteria. Therefore, only the PFAS that have been scientifically and individually investigated have been added to the SIN List in the past.
There is, however, a growing consensus that we need to move beyond individual hazard assessments of chemicals and look more at the group level. PFAS is the first group of chemicals where scientists and most other stakeholders agree that they should be tackled on a group level.
The most problematic property — the extreme persistence — is undoubtfully shared across the PFAS group. Other properties such as toxicity, mobility and bioaccumulation vary amongst the individual chemicals depending on the chemical structure. But there is no evidence suggesting the existence of “safe” PFAS substances.
Is a non-SIN List PFAS safe?
No, all PFAS chemicals are undoubtfully extremely problematic. The reduction of the PFAS universe for the SIN List is done with the aim to provide a list of well-defined and relevant PFAS so that these can be communicated in supply chains and targeted for testing and phase-out.
Frequently Asked Questions
What is the SIN List?
The SIN List is a list of hazardous chemicals that are used in a wide variety products and manufacturing processes around the globe. The SIN abbreviation – Substitute It Now – implies that these chemicals should be removed as soon as possible as they pose a threat to human health and the environment.
But the SIN List is more than just a list of chemicals. It’s a tool to facilitate chemicals management and a perfect starting point for any organisation committed to identifying and substituting hazardous chemicals with safer alternatives.
The SIN List consists of chemicals that ChemSec have identified as fulfilling the criteria for Substances of Very High Concern as defined by the EU chemicals regulation REACH. The list is based on credible, publicly available information from existing databases and scientific studies, as well as new research.
Who has developed the SIN List?
The SIN List has been developed by ChemSec, a non-profit organisation working to substantially reduce the use of hazardous chemicals and its impact on human health and the environment. ChemSec was founded in 2002 by environmental organisations and is funded by grants from authorities and foundations.
The development of the SIN List has been carried out in close collaboration with scientists and technical experts and guided by an NGO advisory committee of leading environmental, health, women and consumer organisations mainly in Europe but also in the US.
What is the connection between the SIN List and REACH?
Within the EU chemicals regulation REACH, the most hazardous chemicals are defined as Substances of Very High Concern. EU member states have decided that the use of these substances should be strictly limited.
However, the process of actually regulating specific chemicals within the scope of REACH has up until now been far too slow.
What are Substances of Very High Concern?
The criteria for Substances of Very High Concern (SVHC) are described in REACH article 57. Three categories are included there, and also the SIN List encompasses substances from these three categories.
- The first category is chemicals that can cause cancer, alter DNA or damage reproductive systems. These are called CMR substances (Carcinogenic, Mutagenic or toxic to Reproduction).
- Then there are substances that cause problems on the longer time scale – toxic substances that do not easily break down but rather accumulate in the food chain. These are known as PBT substances (Persistent, Bio-accumulative and Toxic). There is also the abbreviation vPvB, short for very Persistent and very Bio-accumulative.
- The third category is called “substances of equivalent level of concern”. This category covers substances that are not automatically covered by the other two categories, but which nonetheless give rise to equivalent level of concern in terms of potential damage. This category includes e.g. endocrine disrupting chemicals (EDCs) and Persistent, Mobile and Toxic chemicals (PMTs).
Why is the SIN List continuously updated?
Over time, new information on the hazardous properties becomes available. The political discussions and the interpretation of REACH criteria can also be slightly modified over time. In order to keep the SIN List up-to-date with the developments, regular updates are needed.
Why are the substances on the SIN List grouped?
The aim of dividing the SIN List into groups is to make the SIN List an even more user-friendly, hands-on tool for progressive chemicals management. As structurally similar substances often share both desired functional properties as well as hazardous properties it can be wise to tackle chemicals group-wise in order to avoid so called regrettable substitution.
Many SIN substances have not even been registered – how can you say that they are relevant?
It is very difficult for anyone not having access to industry data to judge how a substance is being used. There are several good reasons to look at non-registered substances as well:
- Not all substances need to be registered. Many hazardous substances could in fact be among the low volume chemicals.
- Hazardous substances that are not registered could still be imported into the EU through articles.
- By addressing these chemicals, we assure that they will not be used in the future.
Where can I find which scientific studies are used for the SIN List?
You cannot find the scientific references for each substance in the SIN List database, but if you send us an email, we are happy to forward the background data for the substances you are interested in. Please note that for substances having already an official classification as being CMR – this is enough for inclusion on the SIN List and we do not have additional background data.
Does ChemSec have a process to delist substances from the SIN List?
If we are presented with new evidence about a substance that could invalid our earlier conclusions, we evaluate this evidence and other evidence published since the addition to the SIN List, to see if the conclusion needs to be changed. We have done this for a few substances, but so far there has been no reason to remove a chemical. In most cases, new data on a hazardous chemical tend to emphasize the hazardous properties rather than the opposite.