Tag Archives: restricted substance

EU – REACH SVHCs added to Candidate List on December 17, 2015

The European Chemical Agency (ECHA), on December 17, 2015, added five new substances to the REACH SVHC Candidate List. The substances are listed in the table below. The Article 33 communication obligations specified in the REACH regulation (Regulation (EC) No 1907/2006) came into effect as soon as the SVHCs were added to the Candidate List,

SVHCs Added to the REACH Candidate List on December 17, 2015

Substance NameEC numberCAS number
1,3-propanesultone214-317-91120-71-4
2,4-di-tert-butyl-6-(5-chlorobenzotriazol-2-yl)phenol (UV-327)223-383-83864-99-1
2-(2H-benzotriazol-2-yl)-4-(tert-butyl)-6-(sec-butyl)phenol (UV-350)253-037-136437-37-3
Nitrobenzene202-716-098-95-3
Perfluorononan-1-oic-acid and its sodium and ammonium salts206-801-3375-95-1, 21049-39-8, 4149-60-4

The substance, Dicyclohexyl phthalate, had been proposed for addition to the Candidate List during this update, but was withdrawn by the dossier submitter (Sweden) and postponed to a later submission date. The substance hexamethylene diacrylate (hexane-1,6-diol diacrylate) had also been proposed for the REACH Candidate List but did not get added. The full Candidate List is available on the ECHA website.

For additional information on developing or assessing an effective REACH SVHC compliance program, contact ECD Compliance.

Two Substances added to REACH SVHC Candidate List

The European Chemical Agency (ECHA), on June 15, 2015, added two new substances to the REACH SVHC Canadidate List. The substances are listed in the table below. The Article 33 communication obligations specified in the REACH regulation (Regulation (EC) No 1907/2006) came into effect as soon as the SVHCs were added to the REACH Candidate List,

Name of Substance or Substance GroupEC number CAS number
1,2-benzenedicarboxylic acid, di-C6-10-alkyl esters; 1,2-benzenedicarboxylic acid, mixed decyl and hexyl and octyl diesters with ≥ 0.3% of dihexyl phthalate (EC No. 201-559-5) 271-094-0
272-013-1		68515-51-5
68648-93-1
5-sec-butyl-2-(2,4-dimethylcyclohex-3-en-1-yl)-5-methyl-1,3-dioxane [1], 5-sec-butyl-2-(4,6-dimethylcyclohex-3-en-1-yl)-5-methyl-1,3-dioxane [2] [covering any of the individual stereoisomers of [1] and [2] or any combination thereof] --

The first substance is a mixture of two alkyl diesters when the mixture contains greater than 0.3% of dihexyl phthlate (DnHP). This SVHC listing will likely be confusing and a challenge for industries to manage. The two primary ingredients with the CAS numbers and EC Tnumbers listed are themselves not SVHCs; the mixture only becomes an SVHC with the Article 33 reporting obligations when it includes greater than 0.3% DnHP.

The second new listing in the REACH Candidate List is a substance group. The primary example listed by ECHA of this substance group is the product sold under the name “karanal” . ECHA indicates that the main use, according to public information, is as a fragrance.

For additional information on developing or assessing an effective REACH SVHC compliance program, contact ECD Compliance.

 

BNST Restriction in Lubricants Takes Effect in Two Months

BNST Restriction in Canada and Impact on EEE Industry

The two-year transition period for the use of BNST (Benzenamine, N-phenyl-, Reaction Products with Styrene and 2,4,4-Trimethylpentene) as a substance in lubricants in products manufactured and imported into Canada is coming to an end on March 14, 2015. Products and parts containing lubricants with BNST may not be imported into Canada after this date. In general, all types of products containing such lubricants (including IT equipoment, consumer electronics and appliances) are impacted by the restriction. BNST has been used in lubricants in motors and other sliding mechanisms in many types of electrical and electronic products to improve performance and reliability.  Additional information on the Regulations is provided below.

Many EEE manufacturers and suppliers have substituted the lubricants in their motors and sliding mechanisms or are in the final stages of qualifying new lubricants and ramping production of the redesigned parts and products. BNST provides benefits in the lubricant as a antioxidant, corrosion inhibitor, scavenger, and anti-scaling agent; therefore, eliminating the BNST can impact performance and long-term reliability which needs to be carefully assessed during substitution.  Another commmon challenge in eliminating BNST has been in getting material declaration information from suppliers. Lubricant manufacturers often consider their formulations to be proprietary so information about constituents may be difficult to obtain.

As products transition to non-BNST lubricants, there will be logistical challenges as existing inventories are used up.  Spare parts, which are also subject to the restrictions, are a particular challenge especially if the absense of BNST cannot be confirmed. It’s quite common that spare parts may no longer be in production and only available from existing inventory, Environment Canada suggested that manfuacturers and importers should use a conservative approach in such situations when it’s not possible to confirm that the product is BNST-free.

Permits for BNST

The Canadian Prohibition of Certain Toxic Substances Regulations, 2012 anticipated that it may not be possible to eliminate BNST for all products and it provides a mechanism for manufactuturers and importers to obtain permits for up to an additional three years if requirements specified in the Regulations are met. If your organization needs additional time to eliminate BNST or to confirm it’s absense, obtaining a permit for March 2015-March 2016 can help reduce business risk and avoid customer issues.

Permit applicatoins must be submitted by the Canadian manufacturer or importer. Permits are granted to the individual organizations that have submitted an application; therefore every organization that needs a permit must submit their own application or participate in a group permit application. The permit application includes requirements for information on BNST use and plans for phasing out the substance from your products.  Environment Canada has stated that applications not meeting specific minimum requirements cannot be approved. ECD Compliance can assist your organization in assessing your situation against the permit requirements specified in the Regulations and to compile the application with the necessary information.

Background Information on the Regulations restricting BNST

BNST is restricted in Canada under the Prohibition of Certain Toxic Substances Regulations, 2012 beginning on March 14, 2013; however, a 2 year exemption for use of BNST as an additive in lubricants has extended the use period for applications in the EEE industry. The Prohibition Regulation is available for download from the Canada Gazette (part II). The regulation bans any intentional use; there is no numerical maximum concentration threshold.