REACH and Substances of Very High Concern

In 2007, the European Union’s new framework policy on industrial chemicals, REACH, entered into force. REACH stands for registration, evaluation, authorisation and restriction of chemicals.

REACH aims to ensure that basic information on industrial chemicals used in the EU is provided and that the use of the most hazardous chemicals is limited or prohibited through either restriction or authorisation procedures. The success of REACH is dependent on a prompt, effective process for identifying the most hazardous chemicals on the European market and replacing them with safer alternatives.

REACH requires companies to register information about the chemicals they produce or import. The registration of pre-REACH substances was divided into three different deadlines; in 2010, 2013 and 2018 depending on production volume and known hazardous properties.

The most hazardous substances in REACH can be designated as Substances of Very High Concern (SVHCs) and after a sunset date their use will only be allowed if authorised.

At the heart of the authorisation process is a Candidate List of chemicals that meet the criteria for Substances of Very High Concern as defined in the legislation, such as those that may cause cancer or persist in our bodies and the environment for long periods of time. Placing a substance on the Candidate List triggers specific obligations for companies to inform downstream users and consumers about the presence of this substance in products in the supply chain.

However, the mere fulfilment of the SVHC criteria does not mean a substance is automatically placed on the Candidate List. In order for a substance to be listed it needs to be nominated by either an EU member state or the European Chemicals Agency (ECHA) on behalf of the European Commission. These must prepare a dossier to justify the reasons for inclusion and then all member states must unanimously decide that it is indeed an SVHC. From the Candidate List, substances are later selected for further scrutiny and eventually restricted or allowed only for specifically authorised purposes.

The EU is populating the Candidate List with SVHC substances, but the process has so far been quite slow and unpredictable, as this is as much a political as a scientific process. The current official Candidate List can be found on the official ECHA website.

The SIN List uses the same criteria as the Candidate List, but is independent on these slow and unpredictable political processes.