The Registration, Evaluation, Authorisation or Restriction of Chemicals Regulation (REACH) has been a data point for compliance since its inception in 2008. The REACH regulation maintains three separate lists with different requirements for the substances called out on each one.
The Candidate List (SVHC)
Most notable for individuals in compliance, REACH is well known for the amount of changes made requiring constant updates in one’s own compliance databases. In fact, the Candidate list for substances of very high concern (SVHC) has been updated 25 times since it was created. Currently, changes occur every 6 months as a new list of substances of very high concern are added to the Candidate list. The most recent update being in January of 2022. If you haven’t updated your compliance declarations, chances are you have an outdated compliance document and a potential risk of noncompliance that may affect your customers.
An SVHC is any substance that is found to be carcinogenic, mutagenic, or toxic to reproductive health through the “evaluation” phase of REACH. Any substance that is persistent, bioaccumulative, and toxic or is very persistent and very bioaccumulative may also become an SVHC. Furthermore, any substance that causes a level of concern relative to the preceding characteristics may become an SVHC.
Why might this ever-changing series of lists be important to your organization? Substances on the Candidate list are required to be disclosed to customers and, via SCIP database, to waste operators and recyclers. However, disclosure is not always the end of the story for SVHC use. SVHCs are on the Candidate list because they become candidates for Authorisation, Annex XIV of the REACH regulation.
Authorisation (Annex XIV)
The Authorisation list identifies substances with an approved use and a “sunset date,” the date from which placing the substance on the EU market would be prohibited unless exempted or an authorisation has been granted. This drives replacement substances to the market, hopefully reducing the use of and exposure to the Authorisation list substances.
The Authorisation list can add new authorisations and change sunset dates for certain substances. Thus, the Candidate List of SVHCs is not the only list of substances that is subject to frequent updates and changes under REACH. As a result of these frequent updates, staying aware of the changes, collecting updated data from your own supply chain, and keeping your compliance documentation current is critical to communicating your compliance status to your own customers.
Restricted (Annex XVII)
Annex XVII of REACH is the Restricted list. This list covers substances that are limited or possibly banned from manufacture or placement on the EU market. Any substance on the Restricted List also contains conditions of the restriction. These conditions may be for specific uses and can also include an outright ban of use. A restriction may apply to a specific substance on its own, in a mixture or preparation, or even in an article.
The Restricted list also adds new restrictions and has previously deleted entries due to ever-changing updates and new regulations. Any effort to comply with the REACH regulation requires ongoing attention to all three lists (Candidate, Authorisation, and Restricted) and comprehensive management of suppliers and material content in order to meet ever-changing requirements and to achieve compliance.
When first learning and understanding REACH regulations, it’s important to know that the REACH regulation’s only consistency is its constant subject to change.
How to Manage Frequent Changes in REACH
The ability to quickly monitor and track the compliance of your products and identify problems is vital to any modern organization with little time to risk non-compliance. Our Green Data Exchange (GDX) system provides real-time streams of updates to your organization immediately, providing an effortless way to maintain compliance, identify risks and create certificates of compliance.