REACH (Registration, Evaluation, Authorization and Restriction of Chemical) / SVHC (Substances of Very High Concern) are imposed by EU as part of their many restrictions on products imported to Europe. Many clients, middlemen, traders and manufacturers do not know clearly of what it is and where it applies. They are pretty much to get it tested or complied on demand basis from their counterpart. Some are wrongly thinking that passing SVHC is sufficient by its own and no need for other testes.
Here, we would like to simplify it from lengthy regulations and provide helpful tips to everyone, in terms of understanding SVHC, REACH list, REACH regulation and REACH compliance.
Firstly, we can understand SVHC from its full description of “Substances of Very High Concern”. The wording “Very High Concern” is not as strong as “prohibited” or “forbidden”, “banned” or “not allowed”, but it is close to. The SVHC description implies that the listed chemicals are not desirable. Althought it is not yet prohibited, but it will.
REACH / SVHC are under EC Directive 1907/2006. The ultimate purpose is to have a list of substances that are potentially harmful to human and environment in the first place. By registration. authorization and tighten control from time to time, it is to phase out those products that contains undesirable chemicals from market or restrict those substance that are at very high risk.
The next compliance date on SVHC would be 6 Jun 2011, which involves 46 substances with limitation at 0.1% or 1000ppm. It applies to the product volume imported to Europe larger than 1 tonnage/year per importer or producer. The importer needs to do a registration with Safety Data Sheet (SDS) of the product that above the 0.1% limitation and need to inform customer on request.
This is totally different from RoHS, which prohibit electronic products to import to Europe if it fails to compliance with it. For REACH / SVHC, the products above the limit are at the moment allowed to be imported in Europe in general, even though it will be tighten or prohibited one day. Just like the annoucement on 17 Feb 2011, six of the named SVHC substances will be prohibited in coming few years. They are highlighted in red in the list below.
The 46 substances are
- Triethyl arsenate
- 4,4’-Diaminodiphenylmethane (MDA)
- Dibutyl phthalate (DBP)
- Cobalt dichloride
- Diarsenic pentaxide
- Diarsenic trioxide
- Sodium dichromate
- 5-tert-butyl-2,4,6,-trinitro-m-xylene (musk xylene)
- Bis (2-ethylhexyl) phthalate (DEHP)
- Hexabromocyclododecane (HBCDD) and all major diastereoisomers identified
- Alkanes, C10-13, chloro (Short Chain Chlorinated Paraffins)
- Bis(tributyltin)oxide (TBTO)
- Lead hydrogen arsenate
- Benzyl butyl phthalate (BBP)
- Anthracene oil
- Anthracene oil, anthracene paste, distn. Lights
- Anthracene oil, anthracene paste, anthracene fraction
- Anthracene oil, anthracene-low
- Anthracene oil, anthracene paste
- Coal tar pitch, high temperature
- Aluminiosilicate, Refractory Ceramic Fibres
- Zirconia Aluminosilicate, Refractory Cerami Fibres
- Diisobutyl phthalate (DIBP)
- Lead chromate
- Lead chromate molybdate sulphate red (C.I. Pigment Red 104)
- Lead sulfochromate yellow (C.I. Pigment Yellow 34)
- Boric acid
- Disodium tetraborate, anhydrous
- Tetraboron disodium heptaoxide, hydrate
- Sodium chromate
- Potassium chromate
- Ammonium dichromate
- Potassium dichromate
- Cobalt(II) sulphate
- Cobalt(II) dinitrate
- Cobalt(II) carbonate
- Cobalt(II) diacetate
- Chromium trioxide
- Acids generated from chromium trioxide and their oligomers: Chromic acid, Dichromic acid, Oligomers of chromic acid and dichromic acid
There are a number of exclusions, please refer to article 2 below.
From the list substances, some are typically exist in certain product or industry and other substances may be totally unrelated. It is obvious that the list is to have a very wide coverage and not targeting particular application or industry.
Therefore, it happens from time to time that SVHC is covering less related harmful substances for an industry comparing to existing standard imposed on particular industry or product. For example, normal PVC testing will involve 6 or more phthalates and SVHC is only covering 4. Electrical and electronic products will need to comply with RoHS and those hazardous substances are not listed in SVHC.
At the moment, it is better to treat SVHC as a supplementary requirement on top of widely accepted standard of a particular industry. In other words, a practical approach at the moment is to comply with industry standard first and add SVHC as supplementary test as a further evidence of safety if needed. In case there is not a proper standard available for the industry such as some pet products, we should comply with commonly prohibited substances such as substance mentioned in RoHS and optionally adding SVHC as required.
It is no doubt that the concern on harmful substance is becoming a more and more important issue for a business. Non-compliance will lead to a business failure. Substances in SVHC will eventually being banned sooner or later. An early compliance, even not required by customer at the moment, is always beneficial and can reduce the risk of a business.