Where are the SVHCs?

Ursula Klaschka

doi:10.1186/s12302-017-0122-0

Abstract

BackgroundThe European chemicals regulation REACH includes the legal duty for suppliers to inform consumers on request about the presence of substances of very high concern (SVHCs) in articles. Since this requirement has been in force now for 10 years, the intention of this study was to find out whether information on SVHCs is adequately communicated to the consumer today. Data on the presence of SVHCs in articles were collected as a prerequisite for the subsequent requests for a targeted choice of articles to examine the operability of the ‘right to know.’ResultsLiterature data show that SVHCs have been measured and described in a large variety of commodities. 32% of 334 information requests for articles which were suspected to contain SVHCs were answered by suppliers and a minor number of these answers were of good quality. Only two respondents indicated the presence of SVHCs in their articles. Suppliers are not legally obliged to respond to requests if their articles are free of SVHCs. Therefore, the absence of a response might be interpreted as an indication that SVHCs are present below 0.1% in the articles in question. However, there are certain doubts that only two out of 334 articles suspected contain SVHCs.ConclusionsThe data question whether the ambitious aims of the SVHC regime can be achieved under the present conditions. Measures are proposed on how to improve implementation of the information requirement and to amend the legal criteria in the upcoming REACH revision.

Highlights

The European chemicals regulation REACH includes the legal duty for suppliers to inform consum‐ ers on request about the presence of substances of very high concern (SVHCs) in articles
Manufacturers who use more than one ton SVHCs per year in articles must submit a notification of this use to ECHA (Table 1, column 1), unless exposure of humans or the environment can be excluded or unless the use is covered in the registration dossier for the substance [1 Art. 7 (2)]
Compliance after 10 years ‘right to know’ The REACH information right for consumers about candidate list substances has been in force for nearly 10 years and several studies have revealed since, that a large number of suppliers do not fulfill their obligations as foreseen

Summary

Introduction

The European chemicals regulation REACH includes the legal duty for suppliers to inform consum‐ ers on request about the presence of substances of very high concern (SVHCs) in articles. Since this requirement has been in force for 10 years, the intention of this study was to find out whether information on SVHCs is adequately communicated to the consumer today. SVHCs are chemicals which are carcinogenic, mutagenic, toxic for reproduction, or very critical for the environment because they are persistent, bioaccumulative and toxic (PBT), or very persistent and very bioaccumulative (vPvB) or which cause concern for other reasons such as endocrine disruptors ([1] Art. 57) They are listed in the so-called candidate list [2] which is updated twice a year (last update 12/01/2017 with a total of 173 entries) and which should include all relevant currently known SVHCs by 2020 [3].

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