sgs reach svhc smart solutions achieve …

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SGS REACH SVHC SMART SOLUTIONSACHIEVE COMPLIANCE BY RISK BASED EVALUATION WITH REASONABLE AND COST EFFECTIVE APPROACH

JANUARY 2015 UPDATE: MAY 2018

AUTHORS

Dr. Jackson Woo, CBiol, MRSBBusiness Manager, Electrical and Electronics Technology, Consumer and Retail SGS Hong Kong Ltd

Mr. Litto TamSenior Technical Services Executive, Electrical and Electronics Technology, Consumer and Retail SGS Hong Kong Ltd

Dr. Udo KrischkeGlobal Technical Manager RSTS & Operation Integrity Manager, Consumer and Retail, Global Competence Support Center SGS Germany GmbH

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ABSTRACTThe purpose of this white paper is to discuss the current challenges of Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Substances of Very High Concern (SVHC) compliance in electrical and electronic (E&E) industry. It provides a brief summary of REACH regulation especially in the scope of SVHC requirement.

CONTENTS

I. EXECUTIVE SUMMARY.......................................................................................................................................................................................................3 II. INTRODUCTION....................................................................................................................................................................................................................4 III. CHALLENGES.........................................................................................................................................................................................................................8 IV. EXISTING APPROACHES..................................................................................................................................................................................................9 V. RISK ASSESSMENT APPROACH.....................................................................................................................................................................................11 VI. SGS SOLUTION....................................................................................................................................................................................................................12 VII. CONCLUSION.......................................................................................................................................................................................................................21 VIII. REFERENCES......................................................................................................................................................................................................................21

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I. EXECUTIVE SUMMARYREACH SVHC is part of a chemical safety and environmental protection regulation that receives relatively high public attention. Product complexity and continuous update of the Candidate List has laid a heavy burden on the E&E industry.

Although existing approaches, such as pure testing and quality management, provide solutions to tackle this issue, these approaches are often resulting in high testing costs and increased use of resources.

Gathering the necessary information about the presence or levels of SVHC in a product can place an additional burden on the supply chain.

Furthermore, the data quality of self declarations is not always as accurate as expected.

Demonstrating compliance with the help of third-party risk evaluation analysis can not only reduce compliance costs, but can also increase confidence in the compliance process.

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REACH AND SVHC

Green compliance regulations have been evolving quickly in recent years, both challenging and burdening the electronic industry. Among these regulations, such as EU RoHS, China RoHS, Korean RoHS, REACH, EU POPs, Battery Directive, Packaging Directive and so on, REACH SVHC belongs to those attracting the most attention.

SVHC are chemical substances with very hazardous intrinsic properties such as carcinogenicity, mutagenicity and toxicity for reproduction (CMR substances).

Substances which are persistent, bioaccumulative and toxic (PBT) or very persistent and very bioaccumulative (vPvB) as well as endocrine disruptor such as phthalates are also identified as SVHC.

II. INTRODUCTION

Under the Regulation (EC) No 1907/2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), chemicals with above-mentioned hazardous properties are identified as SVHC and would be added to the Candidate List by the European Chemicals Agency (ECHA) and may later become subject to authorisation across the European Union (EU) and added to REACH Annex XIV.

THE CANDIDATE LIST

Among industry, SVHC generally refers to chemicals listed in the Candidate List and the Consultation List of Substances of Very High Concern for Authorisation under REACH. An online “Candidate List of Substances of Very High Concern for authorisation” can be found in ECHA website at: http://echa.europa.eu/candidate-list-table.

Since 28th October 2008, 183 SVHC have been listed in the Candidate List for Authorisation (until 17th April, 2018). Starting from 2011, the Candidate List has been updated twice a year. According to the SVHC roadmap to 2020 implementation plan published by ECHA in 2013, all relevant currently known SVHCs have to be included in the Candidate List by 2020 as committed by former Vice-President Tajani and former Commissioner Potocnik. The number of SVHC in the Candidate List is foreseen to increase continuously while new SVHCs are identified continuously as well.

Even if a SVHC will be added to the Authorisation list of REACH Annex XIV, it will still remain on the SVHC Candidate List. Until 16th June, 2017 there have been 43 entries of SVHC included in authorization list of Annex XIV. Some sunset-dates of unauthorised substance use date back to August 2014.

The inclusion of SVHC in the Candidate List creates legal obligations to companies manufacturing, importing or using such substances, in mixtures or even in articles. This obligation is directly applicable to all EU Member States and the European Economic Area (EEA).

It applies to all chemicals - not only those used in industrial processes, but also those found in products in our daily lives. These products include cleaning products, paints and consumer goods such as clothes, furniture and electrical appliances.

THE AUTHORISATION LIST

Once included in Authorisation List, the substance will not be allowed to be placed on the market or used after a date to be set (the so-called “sunset date”) unless the company is granted an authorisation. The authorisation process seeks to ensure that the risks from substances of very high concern are properly controlled and that the substances are progressively replaced. The current authorization list is shown in table 2. An online “ List of substances included in Annex XIV of REACH (“Authorisation List”)” can be found in ECHA website at: https://echa.europa.eu/authorisation-list.

The Authorization is applied for the use of substance either itself, in mixture or present in article manufactured in EU. However, the Authorization is not applicable for imported articles.

In general, the Authorization procedure consists of two steps:

1. ECHA: publish a candidate list of substance(Annex XIV)

2. Manufacturer / Importer / Only Representative: apply for authorization in use of substances listed in Annex XIV with a proposal of possible substitution plan

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REVISION DATE DETAILS

28 Oct 2008 15 SVHC Candidate List is published

13 Jan 2010 14 additional SVHC are added to SVHC Candidate List

30 Mar 2010 Acrylamide is added to the SVHC Candidate List

18 Jun 2010 8 chemical substances are added to the SVHC Candidate List

15 Dec 2010 8 chemical substances are added to the SVHC Candidate List

18 Feb 2011 Authorization List is published with initial 7 substances

20 June 2011 7 chemical substances are added to the SVHC Candidate List

19 Dec 2011 20 chemical substances are added to the SVHC Candidate List

18 Jun 2012 13 substances are added to Consultation List

The Candidate List has reached 73 SVHC

15 Feb 2012 The Authorization List has reached 14 substance entries

3 Sep 2012 54 substances are added to Consultation List

The Candidate List has reached 84 SVHC

19 Dec 2012 The Candidate List has reached 138 SVHC

4 Mar 2013 10 substances are added to Consultation List

18 Apr 2013 The Authorization List has reached 22 substance entries

20 June 2013 The Candidate List has reached 144 SVHC




16 Jun 2014 The Candidate List has reached 155 SVHC

19 Aug 2014 The Authorization List has reached 31 substance entries







29 Feb 2016 4 substances are added to Consultation List



12 Jan 2017 The Candidate List has reached 173 SVHC

9 Mar 2017 2 substances were added to Consultation List

14 Jun 2017 The Authorization List has reached 43 substance entries

7 Jul 2017 The Candidate List has reached 174 SVHC

5 Sep 2017 9 substances were added to Consultation List

Jan 2018 The Candidate List has reached 181 SVHC

8 Mar 2018 8 substances were added to Consultation List

17 Apr 2018 The Candidate List has reached 183 SVHC

Table 1 shows the history of updates for the Candidate List, Consultation List and Authorisation List

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SUBSTANCES NAME EC NO. / CAS NO. ENTRY NO. LAST APPLICATION DATE SUNSET DATE

5-tert-butyl-2,4,6-trinitro-m-xylene (Musk xylene)

201-329-4 / 81-15-2 1 21/02/2013 21/08/2014

4,4’- Diaminodiphenylmethane (MDA) 202-974-4 / 101-77-9 2 21/02/2013 21/08/2014

Hexabromocyclododecane (HBCDD)

and all major diastereoisomers identified

Hexabromocyclododecane EC no.: 247-148-4 | CAS no.: 25637-99-4

1,2,5,6,9,10-hexabromocyclodecane EC no.: 221-695-9 | CAS no.: 3194-55-6

alpha-hexabromocyclododecane EC no.: - | CAS no.: 134237-50-6

beta-hexabromocyclododecane EC no.: - | CAS no.: 134237-51-7

gamma-hexabromocyclododecane EC no.: - | CAS no.: 134237-52-8

-/- 3 21/02/2014 21/08/2015

Bis(2-ethylhexyl) phthalate (DEHP) 204-211-0 / 117-81-7 4 21/08/2013 21/02/2015

Benzyl butyl phthalate (BBP) 201-622-7 / 85-68-7 5 21/08/2013 21/02/2015

Dibutyl phthalate (DBP) 201-557-4 / 84-74-2 6 21/08/2013 21/02/2015

Diisobutyl phthalate (DIBP) 201-553-2 / 84-69-5 7 21/08/2013 21/02/2015

Diarsenic trioxide 215-481-4 / 1327-53-3 8 21/11/2013 21/05/2015

Diarsenic pentaoxide 215-116-9 / 1303-28-2 9 21/11/2013 21/05/2015

Lead chromate 231-846-0 / 7758-97-6 10 21/11/2013 21/05/2015

Lead sulfochromate yellow 215-693-7 / 1344-37-2 11 21/11/2013 21/05/2015

Lead chromate molybdate sulfate red 235-759-9 / 12656-85-8 12 21/11/2013 21/05/2015

Tris(2-chloroethyl) phosphate 204-118-5 / 115-96-8 13 21/02/2014 21/08/2015

2,4-dinitrotoluene (2,4-DNT) 204-450-0 / 121-14-2 14 21/02/2014 21/08/2015

Trichloroethylene 201-167-4 / 79-01-6 15 21/10/2014 21/04/2016

Chromium trioxide 215-607-8 / 1333-82-0 16 21/03/2016 21/09/2017

Acids generated from chromium trioxide and their oligomers

show/hide

Chromic acid EC no.: 231-801-5 | CAS no.: 7738-94-5

Dichromic acid EC no.: 236-881-5 | CAS no.: 13530-68-2

Oligomers of chromic acid and dichromic acid EC no.: - | CAS no.: -

-/- 17 21/03/2016 21/09/2017

Sodium dichromate 234-190-3 / 10588-01-9, 7789-12-0

18 21/03/2016 21/09/2017

Potassium dichromate 231-906-6 / 7778-50-9 19 21/03/2016 21/09/2017

Ammonium dichromate 232-143-1 / 9/5/7789 20 21/03/2016 21/09/2017

Potassium chromate 232-140-5 / 7789-00-6 21 21/03/2016 21/09/2017

Sodium chromate 231-889-5 / 11/3/7775 22 21/03/2016 21/09/2017

Formaldehyde, oligomeric reaction products with aniline

500-036-1 / 25214-70-4 23 22/02/2016 22/08/2017

Arsenic acid 231-901-9 / 7778-39-4 24 22/02/2016 22/08/2017

Bis(2-methoxyethyl) ether 203-924-4 / 111-96-6 25 22/02/2016 22/08/2017

1,2-dichloroethane (EDC) 203-458-1 / 107-06-2 26 22/05/2016 22/11/2017

2,2'-dichloro-4,4'-methylenedianiline (MOCA)

202-918-9 / 101-14-4 27 22/05/2016 22/11/2017

Dichromium tris(chromate) 246-356-2 / 24613-89-6 28 22/07/2017 22/01/2019

Strontium chromate 232-142-6 / 7789-06-2 29 22/07/2017 22/01/2019

Table 2 shows the Authorisation List as of June 14, 2017

https://echa.europa.eu/substance-information/-/substanceinfo/100.001.210









































https://echa.europa.eu/authorisation-list

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REACH SVHC REQUIREMENTS

The ultimate objective of REACH is to ensure a high level of protection of human health and the environment against risks from chemicals, as well as to ensure free circulation of the chemicals on the markets, while enhancing competitiveness and innovation. Under this regulation, every producer, importer and supplier bears responsibility for their products’ safeness, especially if the products contain SVHC with serious human health or environmental concerns.

There are two major obligations for all suppliers related to SVHC. One of the obligations is the communication of information in the supply chain, according to Article 33. Manufacturers and importers of articles, including E&E products, containing SVHC from the Candidate List in a concentration above 0.1% weight by weight, shall provide the recipient of the articles with sufficient information to allow safe use of the articles.

Relevant information shall also be provided to a consumer within 45 days on request. In addition, it is stated in Article 7.2 that any producer or importer of articles shall notify ECHA of all the articles supplied, where the Candidate List substance content exceeds 0.1% and contains more than one tonne of that substance during a year. In response to these requirements, suppliers, manufacturers and importers need to have a comprehensive understanding of the presence of any SVHC in the components and/or articles they manufacture or sell.

CLARIFICATION OF THE ARTICLE INTERPRETATION

The threshold limit (0.1%) of the SVHC substance applied to the article which determine whether the article manufacturer and the importer need to take further actions such as

communication and notification under Article 33 and Article 7(2) respectively as Mentioned in previous paragraph.

The EU REACH Regulation defines an article as an object which during production is given a special shape, surface or design which determines its function to a greater degree than does its chemical composition. There was a long time ongoing debate about whether the threshold limit shall be applied to the entire product or the components parts the product is made of.

On September 10th, 2015, the Court of Justice of the European Union (CJEU) has made a final judgment redefining the interpretation of what constitutes an article. CJEU ruled that the obligation on SVHC in an article as set in Article 7 and 33 under REACH applies to ‘each article in finished good’ (each component in an entire product) rather than to the final product good.

SUBSTANCES NAME EC NO. / CAS NO. ENTRY NO. LAST APPLICATION DATE SUNSET DATE

Potassium hydroxyoctaoxodizincatedichromate

234-329-8 / 11103-86-9 30 22/07/2017 22/01/2019

Pentazinc chromate octahydroxide 256-418-0 / 49663-84-5 31 22/07/2017 22/01/2019

1-bromopropane (n-propyl bromide) 203-445-0 / 106-94-5 32 4/1/2019 4/7/2020

Diisopentyl phthalate 210-088-4 / 605-50-5 33 4/1/2019 4/7/2020

1,2-Benzenedicarboxylic acid, di-C6-8-branched alkyl esters, C7-rich

276-158-1 / 71888-89-6 34 4/1/2019 4/7/2020

1,2-Benzenedicarboxylic acid, di-C7-11-branched and linear alkyl esters

271-084-6 / 68515-42-4 35 4/1/2019 4/7/2020

1,2-Benzenedicarboxylic acid, dipentyl ester, branched and linear

284-032-2 / 84777-06-0 36 4/1/2019 4/7/2020

Bis(2-methoxyethyl) phthalate 204-212-6 / 117-82-8 37 4/1/2019 4/7/2020

Dipentyl phthalate 205-017-9 / 131-18-0 38 4/1/2019 4/7/2020

N-pentyl-isopentylphthalate / 776297-69-9 39 4/1/2019 4/7/2020

Anthracene oilA complex combination of polycyclic aromatic hydrocarbons obtained from coal tar having an approximate distillation range of 300°C to 400°C (572°F to 752°F). Composed primarily of phenanthrene, anthracene and carbazole.

292-602-7 / 90640-80-5 40 4/4/2019 4/10/2020

Pitch, coal tar, high-temp.The residue from the distillation of high temperature coal tar. A black solid with an approximate softening point from 30°C to 180°C (86°F to 356°F). Composed primarily of a complex mixture of three or more membered condensed ring aromatic hydrocarbons.

266-028-2 / 65996-93-2 41 4/4/2019 4/10/2020

4-(1,1,3,3-tetramethylbutyl)phenol, ethoxylatedcovering well-defined substances and UVCB substances, polymers and homologues

- / - 42 4/7/2019 4/1/2021

4-Nonylphenol, branched and linear, ethoxylatedsubstances with a linear and/or branched alkyl chain with a carbon number of 9 covalently bound in position 4 to phenol, ethoxylated covering UVCB- and well-defined substances, polymers and homologues, which include any of the individual isomers and/or combinations thereof

- / - 43 4/7/2019 4/1/2021





















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Although manufacturers and importers of basic chemicals/mixture are with most obligations at all stages of REACH, the Regulation has also introduced a number of obligations as mentioned above for the downstream users of chemicals. For example, non-chemical sectors, such as E&E industry, involve manufacturing/importing activities that lead to the production/import of final products containing SVHCs. Distributors and retailers using their own brands are also obligated to deliver information along the supply chain and passing information on to consumers. The REACH Regulation is a very demanding system for any business either large or small, which are directly or indirectly involved with the chemical industry.

III. CHALLENGESIn view of the fast-growing number of SVHC in the Candidate List as well as the tightened legal enforcement reflected in, for example, announcement of penalty of violation in Belgium and Germany, there is increasing market concern about the presence of SVHC in products. Although the REACH Regulation is only applicable to EU manufacturers and importers, non-EU manufactures may still be charged for substantial compensation by EU importers due to the products non-compliance regarding REACH. Therefore, to reduce the massive impacts caused by REACH on EU trade, it is of great significance for companies to actively comply with the REACH Regulation.

Recently, the EU LIFE project AskREACH has been launched by the European population the German Environment Agency (UBA) to promote the public awareness of the REACH consumer right. This is a collaboration program between20 project partners from 13-member states.

EU MEMBER STATES PENALTIES

Belgium Fine not exceeding €55,000,000

Imprisonment not exceeding 3 years

Czech Republic Fine up to CZK 5,000,000 (€195,695)

Denmark Fine (proportional to the perpetrator’s daily income)

Imprisonment up to 2 years

France Fine up to €375,000 & daily periodic penalty €1,500

Germany Fine up to €1,000,000


Hungary Fine up to HUF50,000,000 (€17,606)

Ireland Fine up to €5,000 and coercive (a periodical fine that can be imposed on a daily, weekly or monthly basis until the REACH provisions are complied with)

Imprisonment not exceeding 2 years

Italy Fine up to €60,000

Netherlands Fine up to €740,000


Norway Fine proportional to the perpetrator’s daily income and coercive (a periodical fine that can be imposed on a daily, weekly or monthly basis until the REACH provisions are complied with)

Imprisonment not exceeding 3 months

Romania Fine up to RON 50,000 (€11,889)

Sweden Fine based on the perpetrator’s daily income & corporate fine up to SEK10,000,000 (€960,157)


United Kingdom Fine up to £5,000 on summary conviction and unlimited on conviction on indictment

Imprisonment up to 3 months on summary conviction and up to 2 years on conviction on indictment

Table 3 shows penalties which may be connected to any REACH violation in some EU member states.

A database will be developed for collecting the SVHC information in articles by article suppliers and which can be accessed by EU citizens through smart phone application. Several large companies have already agreed to participate in this project and will share their data to the database. Similar projects are proposed for the future and will eventually raise the awareness of the public concern on SVHC.

Besides the voluntary actions done by the industries. The ECHA Enforcement Forum will also act to check articles for compliance with REACH requirements for substances in articles. The inspectors will co-operate with customs authorities and focus on duties to notify substances of very high concern (SVHCs) in articles and the requirements for communicating information on SVHCs in the supply chain. The target articles do not only limit to those made in EU but also the imported articles.

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Suppliers, manufacturers and importers may make use of different approaches to acquire information they require to fulfil the REACH SVHC requirements. Across the E&E industry, there are two principal approaches, including testing and non-testing (quality management, database etc.). Traditional laboratory testing is the most widely adopted method these days.

ANALYTICAL SCREENING APPROACH

Analytical screening approach involves the application of multifold state-of-the-art quantification chemical analytical technology. Gas chromatography - mass spectrometry (GC/MS), Liquid chromatography - mass spectrometry (LC/MS) and Inductively Coupled Plasma Optical Emission Spectrometry (ICP-OES), among others, are common analytical instruments to be used. Determination of the SVHC chemicals directly or by making use of tracer substances, the analytical approach allows identification but also quantification of SVHC in articles.

It provides conclusive and reliable information whether an individual article or a complex product assembly fulfils the SVHC requirement of REACH Regulation. It is applicable to all materials, components and products regardless of its complexity. It allows a complete reveal of SVHC in the product by applying analytical methods. The test results give strong evidence of the presence of SVHC in the product.

By simply testing the finished product, it also relieves the burden on chemical hazard management systems throughout the production process. It can also serve to obtain information needed for compliance with REACH. However, it should be noted that the analytical approach may yield ambiguous results and it is time and cost demanding. During a single extraction processes, it is also possible that the target substances may not be thoroughly extracted. This means the full picture of the harmful substances content may not be completely revealed in a first screening approach.

IV. EXISTING APPROACHESSome testing methods, moreover, may not represent the existence of the substances, as the results only show the presence of certain tracer elements. For instance, halogens and heavy metals identification. Normally, a series of analyses need to be performed in order to identify the exact number of substances contained in an article. Sometimes, additional instrumental measurements are required for further quantification.

Because of those difficulties mentioned above, a meaningful test approach needs expert knowledge and it is often not possible to perform such analytical testing by the manufacturer. SVHC testing very often is outsourced for external third-party testing laboratory.

As analytical approach provides clear and strong evidence despite of its relatively high demand on testing cost and time, it has remained the most common and direct strategy regarding REACH SVHC compliance among E&E industry. One of the reasons is that, despite mentioned test cost and time, it is sometimes the only way to obtain information where the communication in the supply chain is not reliable.

NON-ANALYTICAL APPROACH

A complex object, such as electrical and electronic equipment, is an assembly of numerous articles, sometimes with additional substances and/or mixtures such as paint and glue.

For products containing such a large number of components or materials, it is inevitably time consuming and costly to employ a final product testing approach. To fulfil the SVHC requirement for complex object, a non-testing approach is commonly adopted. This approach involves requesting information at material or component level up the supply chain, which is usually provided by suppliers in the form of compliance certificates and/or full material declaration (FMD). Actual testing on the assembled product is usually not performed.

For compliance certificates, the producer of a complex product would often request that suppliers provide the compliance report or declaration at material or component level. If every article of the product does not contain more than 0.1% by weight of SVHC, it can safely be concluded that the final product can fulfil the SVHC <0.1% requirement.

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For FMD, the producer of a complex product would require their component suppliers to disclose the percentage weight of each individual article in the part and the percentage weight of each substance which is intentionally added to each material. It requires complete disclosure of the material formulation.

Producers at the final product level can analyse the FMD data of all components for SVHC compliance. Whenever there is any update on the Candidate List, compliance can be determined by re-calculation using the FMD data already collected. When the product design is changed, SVHC compliance can be determined following the collection of FMD data for any newly added components. FMD provides information about materials and additives in each article of complex object.

However, impurities and contaminants, which are quite common origins of outbreaks, or SVHC formed as products from a chemical process during a manufacturing step may neither be found nor declared. The possible presence of inadvertently introduced SVHC might be neglected by the FMD approach.

Moreover, FMD arouses concerns as regards treatment of confidential business information (CBI). As FMD requires disclosure of detailed product information, down to the substance level along the supply chain, some may be worried that this valuable information would be copied by competitors.

This, in general, is the major reason why the FMD approach cannot be adopted thoroughly and in turn leads to incomplete FMD and insufficient information for the determination of SVHC compliance for the final product. A reliable internal quality management system plays a very critical role for the implementation of non-testing approach which involves a huge and complicated professional database.

Both FMD and collection of compliance statements of component parts have to be incorporated as part of incoming quality control policy. In some cases, both compliance statements and FMD are collected through a single system.

There are some FMD system service providers in the market. Data collection service is usually provided through an online database. Suitable software is used to calculate amount of any SVHC contained in the final product from FMD data of components at various levels.

Some FMD tools may also allow users to make certain FMD confidential to certain information receivers. Nevertheless, this does not reduce the complexity of FMD or the worry about CBI disclosure.

Another major concern about non-testing approach is the reliability of information provided by suppliers. The accuracy and trustworthiness of supplier declarations are sometimes questionable. These are the reasons why the non-testing approach cannot, for now, replace the traditional testing approach. There is still great demand in the industry for a simple and cost effective SVHC solution.

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SVHC contained in articles can be identified and quantified by applying analytical methods. Laboratory testing, which provides more reliable and concrete evidence to show if, and in what concentrations, any SVHC in the Candidate List is contained in an article, remains the most widely adopted approach, as it provides a more direct and simple way of handling. However, with an increasing number of Candidate List substances and complexity of E&E products, traditional laboratory testing on E&E products is highly demanding in terms of both time and money.

Although SVHC compliance can also be tackled through the quality management system as mentioned above, due to the complexities of both supply chain and manufacturing process, SVHC may be intentionally or advertently introduced into E&E products. The accuracy and trustworthiness of supplier declarations are always questionable.

V. RISK ASSESSMENT APPROACHData collection along the supply chain may not be comprehensive enough and/or slow and cumbersome. Solely relying on supply chain information is insufficient to minimise the risk of non-compliance. In recent years, there has been increasing demand for reasonable and cost effective approaches to address SVHC compliance issues.

Considering the fact that not all SVHC can be found in E&E products, a product risk assessment based approach seems to be a more cost-effective, intelligent and reasonable strategy.

Through product risk assessment, SVHC relating to E&E products can be identified and monitoring can focus on the relevant SVHC.

Compared with traditional laboratory testing, which covers the whole product with reference to the entire Candidate List, the compliance cost would be lower, as resources allocated

for irrelevant SVHC and materials/components with very low risk can be minimised. In addition, this risk assessment approach could also greatly reduce complexity, when compared to a quality management strategy, which demands comprehensive information from across the supply chain.

Information requests would be more specifically targeted at those high risk materials and components. However, the product risk assessment approach would require expertise with comprehensive knowledge about the potential application of SVHC to the product. This technical competence may not be sufficient for some product manufacturers.

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In view of increasing demand on product risk assessment which is more cost-effective and reasonable, SGS is now offering SVHC Evaluation Analysis (SEA) and Component Article Screening programs specifically designed for E&E products.

Different from conventional approaches, SEA program couples product-specific statistical evaluation with confirmatory testing (Figure 1), based on the vast amount of SGS SVHC test data and expert knowledge on potential SVHCs application in E&E products (Table 4).

VI. SGS SOLUTION

For our High-Risk Screening service, we help clients to narrow down the number of articles where testing is advisable. We combine data from literature with our own testing expertise to identify all SVHCs that might be present in E&E products in addition to

an acceptable quality level sampling approach. This means that testing is then only conducted for those high risk SVHCs identified, and noted as present in quantities greater than 0.05% weight by weight (The assessment base is the weight of an article, as defined under REACH).

Figure 1 shows the workflow of SEA service

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SUBSTANCES EC NO. / CAS NO. COMMON APPLICATION

(EU) 2018 / 636 (PUBLISHED IN APR, 2018)

Dicyclohexyl phthalate (DCHP) 201-545-9 / 84-61-7

As plasticisers in plastisol and in PVC, rubber and plastic articles; As phlegmatizer and as a dispersing agent for formulations of organic peroxides; In fillers, putties, plasters and modelling clay; In adhesives, sealants, coatings and paints, thinners, paint remover and finger paints

(EU) 2018 / 594 (PUBLISHED IN APR, 2018)

Benzene-1,2,4-tricarboxylic acid 1,2 anhydride (trimellitic anhydride) (TMA)

209-08-0 / 552-30-7

As a synthesis of plasticizer in PVC resin; As a reactant in wire and cable insulation enamels and polyester resins in powder coatings; As an epoxy curing agent, textile sizing agent, rubber curing accelerator, electrostatic toner binder, and vinyl cross-link agent

18TH SVHC CANDIDATE LIST (PUBLISHED IN JAN, 2018)

Chrysene 205-923-4 / 218-01-9Not produced intentionally but occurs as a constituent or impurity in coal and petroleum stream substances

Cadmium hydroxide 244-168-5 / 21041-95-2

Use in laboratory chemicals; Manufacture of electrical, electronic and optical equipment; Manufacture of flooring, furniture, toys, construction materials, curtains, footwear, leather products, paper and cardboard products

Cadmium carbonate 208-168-9 / 513-78-0

pH regulator; Use in water treatment products, laboratory chemicals, cosmetics and personal care products; Manufacture of plastics for food packaging and storage, toys, mobile phones and coatings for cable; Additive for glass

Cadmium nitrate 233-710-6 / 10325-94-7Use in laboratory chemicals; Manufacture of glass, porcelain and ceramic products

Benz[a]anthracene 200-280-6 / 56-55-3Not produced intentionally but occurs as a constituent or impurity in coal and petroleum stream substances

1,6,7,8,9,14,15,16,17,17,18,18 Dodecachloropentacyclo [12.2.1.16,9.02,13.05,10]octadeca-7,15-diene (Dechlorane PlusTM) [covering any of its individual anti- and syn-isomers or any combination thereof]

-/-

Non-plasticizing flame retardant for plastics, electronic wiring and cables, automobiles, hard plastic connectors and plastic roofing material; Use in adhesives and sealants; Use in binding agents

Reaction products of 1,3,4-thiadiazolidine-2,5-dithione, formaldehyde and 4-heptaphenol, branched and linear (RP-HP) [with ≥0.1% w/w 4-heptylpheno, branched and linear]

-/-Corrosion inhibitors in lubricant additives, lubricants and greases

17TH SVHC CANDIDATE LIST (PUBLISHED ON JUL 7TH, 2017)

Perfluorohexane-1-sulphonic acid and its salts (PFHxS)

-/-Plasticiser, lubricant, surfactant, wetting agent, corrosion inhibitor and in fire-fighting foams.

16TH SVHC CANDIDATE LIST (PUBLISHED ON JAN 12TH, 2017)

4,4’-isopropylidenediphenol (bisphenol A; BPA)

201-245-8/ 80-05-7Manufacture of polycarbonate, epoxy resins and chemicals; hardener in epoxy resins

Nonadecafluorodecanoic acid (PFDA) and its sodium and ammonium salts

206-400-3/335-76-2-/3830-45-3221-470-5/3108-42-7

Lubricant, wetting agent, plasticiser and corrosion inhibitor

p-(1,1-dimethylpropyl)phenol 201-280-9/80-46-6 Manufacture of chemicals and plastic products

4-heptylphenol, branched and linear [substances with a linear and/or branched alkyl chain with a carbon number of 7 covalently bound predominantly in position 4 to phenol, covering also UVCB- and well-defined substances which include any of the individual isomers or a combination thereof]

-/-Manufacture of polymers; formulation into lubricants

Table 4 shows the latest Candidate List with potential SVHC applications as of April 17th, 2018

1 Incomplete list of potential applications in E&E products, materials or production processes. Other uses of mentioned SVHC may apply.

https://echa.europa.eu/candidate-list-table

14


15TH SVHC CANDIDATE LIST (PUBLISHED ON JUN 20TH, 2016)

Benzo[def]chrysene (Benzo[a]pyrene) 200-028-5 /50-32-8Occur as a by-product or impurity in plastic, rubber, coatings, extender oils and carbon black

14TH SVHC CANDIDATE LIST (PUBLISHED ON DEC 17TH, 2015)

1,3-propanesultone 214-317-9 / 1120-71-4Used as an intermediate; Use in the electrolyte fluid in the production of lithium ion batteries

2,4-di-tert-butyl-6-(5-chlorobenzotriazol-2-yl)phenol (UV-327)

223-383-8 / 3864-99-1UV-stabilizer for plastic, polyurethanes and rubber, used in the formulation of coating

2-(2H-benzotriazol-2-yl)-4-(tert-butyl)-6- (sec-butyl)phenol (UV-350)


Nitrobenzene 202-716-0 / 98-95-3 Used as an intermediate, processing aid, solvent

Perfluorononan-1-oic-acid and its sodium and ammonium salts

206-801-3/375-95-1, 21049-39-8, 4149-60-4

Used as surfactant, cleaning agent, waterproofing agents, used in liquid crystal display panels.


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

Rubber and plastic articles, coatings, paints, adhesives, lubricants

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]

-/- Fragrance ingredient


Cadmium fluoride# 232-222-0 / 7790-79-6 Electrical equipment

Cadmium sulphate#233-331-6 / 10124-36-4, 31119-53-6

Battery, electroplating

2-benzotriazol-2-yl-4,6-di-tertbutylphenol(UV-320)


2-(2H-benzotriazol-2-yl)-4,6-ditertpentylphenol (UV-328)


2-ethylhexyl 10-ethyl-4,4-dioctyl-7-oxo-8-oxa-3,5-dithia-4-stannatetradecanoate (DOTE)

239-622-4 / 15571-58-1 PVC heat stabiliser

Reaction mass of 2-ethylhexyl10-ethyl-4,4-dioctyl-7-oxo-8-oxa-3,5-dithia-4-stannatetradecanoate and 2-ethylhexyl 10-ethyl-4-[[2-[(2-ethylhexyl)oxy]-2-oxoethyl]thio]-4-octyl-7-oxo-8-oxa-3,5-dithia-4-stannatetradecanoate (Reaction mass of DOTE and MOTE)

- / - PVC heat stabiliser


1,2-Benzenedicarboxylic acid, dihexyl ester, branched and linear

271-093-5 / 68515-50-4Plasticizer, sealant / jointing agents, stabilizer in engine oil

Sodium perborate; perboric acid, sodium salt # 239-172-9;234-390-0 / -- Bleaching agent, cleaning agent

Sodium peroxometaborate # 231-556-4 / 7632-04-4 Bleaching agent, cleaning agent

Cadmium chloride # 233-296-7 / 10108-64-2Stabilizer in plastic, used for production of photovoltaic modules, used for production of other cadmium compounds

15



Cadmium sulphide # 215-147-8 / 1306-23-6Pigment, semiconductor industry, stabilizer in plastic

C.I. Direct Black 38 217-710-3 / 1937-37-7 Dye

Dihexyl phthalate 201-559-5 / 84-75-3 Plasticizer

Imidazolidine-2-thione (2-imidazoline-2-thiol) 202-506-9 / 96-45-7 Rubber products and tyres

Trixylyl phosphate 246-677-8 / 25155-23-1 Flame retardant in plastic, additive in lubricant

C.I. Direct Red 28 209-358-4 / 573-58-0 Dye, pH indicator

Lead di(acetate) 206-104-4 / 301-04-2 Pigment, semiconductor industry


Cadmium # 231-152-8 / 7440-43-9 Battery electrodes, anti-corrosive coating, catalysts, alloys and solar cells, pigments, stabilizers for plastics and polymers

Ammonium pentadecafluorooctanoate (APFO)

223-320-4 / 3825-26-1 Fluoropolymers and fluoroelastomers, emulsifiers in the production of non-stick coating of cookware

Pentadecafluorooctanoic acid (PFOA) 206-397-9 / 335-67-1 Fluoropolymers and fluoroelastomers, emulsifiers in the production of non-stick coating of cookware

Dipentyl phthalate (DPP) 205-017-9 / 131-18-0/ Plasticizer in PVC

4-Nonylphenol, branched and linear, ethoxylated

-- / -- Mining, detergent, paints, lacquers and varnishes, leather and textile processing

Cadmium oxide # 215-146-2 / 1306-19-0 Battery electrodes, anti-corrosive coating, glasses, alloys and photo-electronics, catalysts, pigments and ceramic glazes, used to increase the heat resistance of polymers


Hexahydromethylphthalic anhydride, Hexahydro-4-methylphthalic anhydride, Hexahydro-1-methylphthalic anhydride, Hexahydro-3-methylphthalic anhydride

247-094-1 / 25550-51-0, 243-072-0 / 19438-60-9,256-356-4 / 48122-14-1,260-566-1 / 57110-29-9

Resin, rubber, polymer

6-Methoxy-m-toluidine (p-cresidine) 204-419-1 / 120-71-8 Intermediate, dye synthesis

Cyclohexane-1,2-dicarboxylic anhydride, cis-cyclohexane-1,2-dicarboxylic anhydride,trans-cyclohexane-1,2-dicarboxylic anhydride

201-604-9 / 85-42-7,236-086-3 / 13149-00-3,238-009-9 / 14166-21-3

Intermediate, resin modifying agent and epoxy resin curing agent

Pyrochlore, antimony lead yellow# 232-382-1 / 8012-00-8 Paint, coating, glass and ceramic products

Henicosafluoroundecanoic acid 218-165-4 / 2058-94-8 Paint, paper, textile, leather

4-Aminoazobenzene 200-453-6 / 60-09-3 Intermediate of dyes

Silicic acid, lead salt# 234-363-3 / 11120-22-2 Glass and enamel products

Lead titanium zirconium oxide# 235-727-4 / 12626-81-2 Optical products, electronic products, electronic ceramic parts

Lead monoxide (lead oxide)# 215-267-0 / 1317-36-8 Glass, ceramic, paint, rubber

o-Toluidine 202-429-0 / 95-53-4 Intermediate

3-Ethyl-2-methyl-2-(3-methylbutyl)-1,3-oxazolidine

421-150-7 / 143860-04-2 Rubber

Dibutyltin dichloride (DBTC) 211-670-0 / 683-18-1 Textile, plastic, rubber

Lead bis(tetrafluoroborate)# 237-486-0 / 13814-96-5 Electroplating, welding, analytical reagent

Lead dinitrate# 233-245-9 / 10099-74-8 Dyes, leather, pigments

Silicic acid, barium salt, lead-doped# 272-271-5 / 68784-75-8 Glass products

Trilead bis(carbonate)dihydroxide # 215-290-6 / 1319-46-6 Paint, coating, ink, plastic

4,4'-Methylenedi-o-toluidine 212-658-8 / 838-88-0 Insulation material, polyurethane adhesives, epoxy resin curing agent

16


Diethyl sulphate 200-589-6 / 64-67-5 Polymer, dyes

Dimethyl sulphate 201-058-1 / 77-78-1 Polymer, dyes

N,N-Dimethylformamide 200-679-5 / 68-12-2 Leather, printed circuit board

4-(1,1,3,3-tetramethylbutyl)phenol, ethoxylated

-- / -- Paint, ink, paper, glue, textiles

4-Nonylphenol, branched and linear -- / -- Paint, ink, paper, glue, rubber

Furan 203-727-3 / 110-00-9 Solvent, organic synthesis

Lead oxide sulfate# 234-853-7 / 12036-76-9 Plastic

Lead titanium trioxide# 235-038-9 / 12060-00-3 Semiconductors, coating, electronic ceramic filter

Bis(pentabromophenyl) ether (DecaBDE) 214-604-9 / 1163-19-5 Flame retardants

Dinoseb (6-sec-butyl-2,4-dinitrophenol) 201-861-7 / 88-85-7 Plastic

1,2-Diethoxyethane 211-076-1 / 629-14-1 Paint, ink, intermediates

N-Methylacetamide 201-182-6 / 79-16-3 Intermediate

Tetralead trioxide sulphate# 235-380-9 / 12202-17-4 Pigments, plastic, battery

Acetic acid, lead salt, basic 257-175-3 / 51404-69-4 Paint, coating, paint strippers, diluents

[Phthalato(2-)]dioxotrilead 273-688-5 / 69011-06-9 Plastic

Tetraethyllead 201-075-4 / 78-00-2 Fuel additive

N-Pentyl-isopentylphthalate -- / 776297-69-9 Plasticizers

Pentalead tetraoxide sulphate# 235-067-7 / 12065-90-6 Plastic, battery

Heptacosafluorotetradecanoic acid 206-803-4 / 376-06-7 Paint, paper, textile, leather

Tricosafluorododecanoic acid 206-203-2 / 307-55-1 Paint, paper, textile, leather

1-Bromopropane (n-propyl bromide) 203-445-0 / 106-94-5 Drugs, dyes, spices, intermediates

Dioxobis(stearato)trilead 235-702-8 / 12578-12-0 Plastic

Pentacosafluorotridecanoic acid 276-745-2 / 72629-94-8 Paint, paper, textile, leather

Methoxyacetic acid 210-894-6 / 625-45-6 Intermediate

Methyloxirane (Propylene oxide) 200-879-2 / 75-56-9 Intermediate

Trilead dioxide phosphonate# 235-252-2 / 12141-20-7 Plastic stabilizer

o-Aminoazotoluene 202-591-2 / 97-56-3 Intermediate

4-Methyl-m-phenylenediamine (toluene-2,4-diamine)

202-453-1 / 95-80-7 Intermediate of dyes, drugs and other organic synthesis

Diisopentylphthalate75-56-9 200-879-2

Plasticizers

1,2-Benzenedicarboxylic acid, dipentylester, branched and linear

210-088-4 / 605-50-5 Plasticizers

Biphenyl-4-ylamine 284-032-2 / 84777-06-0 Intermediate of dyes and pesticides

Fatty acids, C16-18, lead salts 202-177-1 / 92-67-1 Plastic

Orange lead (lead tetroxide)# 292-966-7 / 91031-62-8 Glass, ceramic, paint, rubber

4,4'-Oxydianiline and its salts 215-235-6 / 1314-41-6 Intermediate of dyes, resin synthesis

Diazene-1,2-dicarboxamide(C,C’-azodi(formamide))

204-650-8 / 123-77-3 Polymer, glue, ink

Sulfurous acid, lead salt, dibasic# 263-467-1 / 62229-08-7 Glass and enamel products

Lead cyanamidate# 244-073-9 / 20837-86-9 Antirust

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α , α -Bis[4-(dimethylamino)phenyl]-4 (phenylamino)naphthalene-1-methanol (C.I. Solvent Blue 4)

229-851-8 / 6786-83-0 Dyes, paints, pigments, inks

1,3,5-tris[(2S and 2R)-2,3-epoxypropyl]-1,3,5-triazine-2,4,6-(1H,3H,5H)-trione (β-TGIC)

423-400-0 / 59653-74-6 Plastic stabilizers, PCB ink, coatings, electrical insulating materials, resin curing agent

N,N,N’,N’-tetramethyl - 4,4’- methylenedianiline (Michler’s base)

202-959-2 / 101-61-1 Dyes, pigments

Diboron trioxide # 215-125-8 / 1303-86-2 Glass and glass fiber, flame retardants, adhesives, inks, paints, coatings, fungicides, insecticides

1,2-bis(2-methoxyethoxy)ethane (TEGDME; triglyme)

203-977-3 / 112-49-2 Solvents, process chemicals

Formamide 200-842-0 / 75-12-7 Intermediates, plasticizers, synthetic leather, inks, solvents

4,4'-bis(dimethylamino)-4''-(methylamino)trityl alcohol

209-218-2 / 561-41-1 Dyes, paints, pigments, inks

Lead(II) bis(methanesulfonate) 401-750-5 / 17570-76-2 Plating

[4-[4,4'-bis(dimethylamino) benzhydrylidene]cyclohexa-2,5-dien-1-ylidene]dimethylammonium chloride (C.I. Basic Violet 3)

208-953-6 / 548-62-9 Textiles, plastics, paints, inks

1,2-dimethoxyethane; ethylene glycol dimethyl ether(EGDME)

203-794-9 / 110-71-4 Batteries, solvents, process chemicals

[4-[[4-anilino-1-naphthyl][4-(dimethylamino)phenyl]methylene]cyclohexa-2,5-dien-1-ylidene] dimethylammonium chloride (C.I. Basic Blue 26)

219-943-6 / 2580-56-5 Inks, dyes, paints, pigments

1,3,5-tris(oxiranylmethyl)-1,3,5-triazine-2,4,6(1H,3H,5H)-trione (TGIC)

219-514-3 / 2451-62-9 Plastic stabilizers, PCB ink, coatings, electrical insulating materials, resin curing agent

4,4'-bis(dimethylamino) benzophenone (Michler’s Ketone)

202-027-5 / 90-94-8 Dyes, pigments, printed circuit boards, polymer


Phenolphthalein 201-004-7 / 77-09-8 Acid base indicator; used in disappearing or color-changing inks or dyes

N,N-dimethylacetamide (DMAC) 204-826-4 / 127-19-5 Used as solvent for resins, gums and various polymers; used in paint strippers, ink removers, coatings and adhesives formulations

4-(1,1,3,3-tetramethylbutyl)phenol 205-426-2 / 140-66-9

Chemical intermediate for surfactant, vulcanization agent and paint; used in the formulation of adhesives; as a monomer for polymer preparations; used in textile auxiliaries, manufacture of nonionic surfactants

Lead diazide, Lead azide# 236-542-1 / 13424-46-9 Used as initiator or booster in detonators for both civilian and military uses and as initiator in pyrotechnic devices

Lead dipicrate 229-335-2 / 6477-64-1 Explosive

1,2-Dichloroethane 203-458-1 / 107-06-2

Used in the production of vinyl chloride monomer for polyvinyl chloride production; solvent for rubber, gums and resins; used in paints, coatings, adhesives, varnishes, soaps, and scouring agents

Calcium arsenate# 231-904-5 / 7778-44-1 Used in metallurgical refinement processes to precipitate nickel from molten copper

18


Dichromium tris(chromate)# 246-356-2 / 24613-89-6 Catalyst in the mordanting of yarns; anti-corrosion paint

2-Methoxyaniline; o-Anisidine 201-963-1 / 90-04-0 Intermediate in the manufacturing of azo dyes, pigments and fragrances; used in tattoo inks, crayon, paper, polymers and aluminum foil

Pentazinc chromate octahydroxide# 256-418-0 / 49663-84-5 Anti-corrosive agent for primer paints, wash primers

Zirconia Aluminosilicate Refractory Ceramic Fibres (ZrAl-RCF) #

-/-Used as insulating fiber for industrial furnaces, pipes, ducts and cables; metal reinforcement

Arsenic acid# 231-901-9 / 7778-39-4

Used in the manufacturing process of glass; βused as wood preservative; desiccant for cotton; used in the production of copper foil for printed circuit boards

Potassium hydroxyoctaoxodizi ncatedichromate#

234-329-8 / 11103-86-9 Anti-corrosion pigment; formulation of coatings and sealants

Formaldehyde, oligomeric reaction products with aniline (technical MDA)

500-036-1 / 25214-70-4

Used as a precursor in the manufacture of methylene diphenyl-diisocyanate (MDI); as a hardener for epoxy resins; intermediate for high performance polymers

Lead styphnate 239-290-0 / 15245-44-0

Used as a primer for small calibre and rifle ammunition; used in munition pyrotechnics, powder actuated devices and detonators for civilian use

Bis(2-methoxyethyl) phthalate 204-212-6 / 117-82-8Plasticizer for food contact polymers; used in adhesives, paint, lacquers, printing inks and varnishes

Trilead diarsenate# 222-979-5 / 3687-31-8 Insecticide; imported in complex byproducts from smelting and refining of nonferrous metal

Aluminosilicate Refractory Ceramic Fibres (Al-RCF) #

-- / --Used as insulating fiber for industrial furnaces, pipes, ducts and cables; metal reinforcement

Bis(2-methoxyethyl) ether 203-924-4 / 111-96-6

Used in leather and metal cleaning; used as solvent for battery electrolytes; used in sealants and adhesives, paint and water-based dyes; used as dispersant for plastics and synthetic rubber

2,2'-dichloro-4,4'-methylenedianiline (MOCA)

202-918-9 / 101-14-4 Used as curing agent, cross-linker, chain extender, pre-polymer for polyurethane elastomers; use in glues, adhesives, and wood sealing


1,2-Benzenedicarboxylic acid, di-C6-8-branched alkyl esters, C7-rich

276-158-1 / 71888-89-6 Plasticizer in plastic, in printing ink for paper, in sealant and adhesive

Strontium chromate# 232-142-6 / 7789-06-2 Component in chrome plating; Pigment and corrosion inhibitor for metal; Colorant for PVC

1,2-Benzenedicarboxylic acid, di-C7-11-branched and linear alkyl esters

271-084-6 / 68515-42-4 Plasticizer in plastic, in sealant and adhesive

1-methyl-2-pyrrolidone 212-828-1 / 872-50-4 Spinning agent for PVC; Coating for metal and wood; Cleaning agent for electronics

1,2,3-trichloropropane 202-486-1 / 96-18-4

Intermediate in chlorinated solvent, which is used in paint, degreaser, glues; Cross-linking agent to manufacture polymers which are used as sealant and rubber production

2-ethoxyethyl acetate 203-839-2 / 111-15-9 Solvent in paints, varnishes, lacquers; Intermediate in chemical industry; Printing for plastic and rubber

Hydrazine 206-114-9 / 302-01-2, 7803-57-8

Synthesis of hydrazine derivatives for using as chemical blowing agent, paints, inks, organic dyes, etc.; Monomer in polymerization for coatings and adhesives; Reducing agent for the deposition of metal on plastics and glass

19



Cobalt(II) diacetate 200-755-8 / 71-48-7 Manufacture of catalysts, surface treatment, alloys, production of pigments, dyes, and rubber adhesion

2-Ethoxyethanol 203-804-1 / 110-80-5 Solvent and chemical intermediate.

Cobalt(II) sulphate# 233-334-2 / 10124-43-3

Manufacture of catalysts and driers, surface treatments (such as electroplating), corrosion prevention, production of pigments, decolourising (in glass, pottery) and batteries.

Chromic acid, Dichromic acid, Oligomers of chromic acid and dichromic acid#

231-801-5, 236-881-5 / 7738-94-5, 13530-68-2

Generated when chromium trioxide is dissolved in water. The uses of these substances are the same as indicated for chromium trioxide.

2-Methoxyethanol 203-713-7 / 109-86-4 Solvent and chemical intermediate.

Chromium trioxide# 215-607-8 / 1333-82-0 Metal finishing and fixing agent

Cobalt(II) carbonate# 208-169-4 / 513-79-1 Manufacture of catalysts, production of pigments, and adhesion.

Cobalt(II) dinitrate# 233-402-1 / 10141-05-6 Manufacture of catalysts, surface treatment and batteries.

3RD SVHC CANDIDATE LIST (PUBLISHED ON JUN 18TH, 2010)

Trichloroethylene 201-167-4 / 79-01-6 Cleaning and degreasing of metal parts or as solvent in adhesives; manufacturing of chlorinated and fluorinated organic compounds.

Potassium Dichromate# 231-906-6 / 7778-50-9 Used for chrome metal manufacturing and as corrosion inhibitor for treatment and coating of metals, etc.

Tetraboron disodium heptaoxide, hydrate # 235-541-3 / 12267-73-1

In detergents and cleaners, in glass and glass fibers, ceramics, industrial fluids, metallurgy, adhesives, flame retardants, personal care products, biocides, fertilisers.

Boric acid#233-139-2, 234-343-4 / 10043-35-3, 11113-50-1

Detergents and cleaners, adhesives, toys, industrial fluids, brake fluids, glass, ceramics, flame retardants, paints, disinfectants, cosmetics, food additives and other products.

Ammonium dichromate# 232-143-1 / 7789-09-5Photosensitive screens manufacturing, metal treatment, oxidising agent, and laboratory analytical agent.

Sodium chromate# 231-889-5 / 7775-11-3An intermediate in the manufacture of other chromium compounds as well as a laboratory analytical agent.

Disodium tetraborate, anhydrous#215-540-4 / 1303-96-4, 1330-43-4, 12179-04-3

In detergents and cleaners, in glass and glass fibres, ceramics, industrial fluids, metallurgy, adhesives, flame retardants, personal care products, biocides, fertilisers.

Potassium chromate# 232-140-5 / 7789-00-6

Corrosion inhibitor for treatment and coating of metals, a colouring agent in ceramics, manufacturing of pigments /inks and laboratory analytical agent.

20


2ND SVHC CANDIDATE LIST (PUBLISHED ON JAN 13TH, 2010, REVISED ON MAR 30TH, 2010)

Acrylamide 201-173-7 / 79-06-1 Synthesis of polyacrylamides

Lead sulfochromate yellow (C.I. Pigment Yellow 34) #

215-693-7 / 1344-37-2 Colouring, painting, coating agent

Lead chromate molybdate sulphate red (C.I. Pigment Red 104) #

235-759-9 / 12656-85-8 Colouring, painting, coating agent

2,4-Dinitrotoluene 204-450-0 / 121-14-2Synthesis of tolunene diisocyanate, which used for manufacturing polyurethane foams

Anthracene oil 292-602-7 / 90640-80-5 Manufacturing other substances such as anthracene and carbon blac, used as reducing agents in blastfurnances, as components in bunker fuel, for impregnating, sealing and corrosion protection.

Anthracene oil, anthracene paste, anthracene fraction

295-275-9 / 91995-15-2

Anthracene oil, anthracene-low 292-604-8 / 90640-82-7

Diisobutyl phthalate (DIBP) 201-553-2 / 84-69-5 Plasticizer

Tris (2-chloroethyl) phosphate (TCEP) 204-118-5 / 115-96-8 Plasticizer, viscosity regulator, flame retardant

Lead chromate# 231-846-0 / 7758-97-6 Pigment, dyes, detergents, bleaches, phtosensitive materials

Anthracene oil, anthracene paste 292-603-2 / 90640-81-6

Manufacturing other substances such as anthracene and carbon blac, used as reducing agents in blastfurnances, as components in bunker fuel, for impregnating, sealing and corrosion protection.

Pitch, coal tar, high temp. 266-028-2 / 65996-93-2 Electrodes, corrosion protection

Anthracene oil, anthracene paste, distn. lights

295-278-5 / 91995-17-4

Manufacturing other substances such as anthracene and carbon blac, used as reducing agents in blastfurnances, as components in bunker fuel, for impregnating, sealing and corrosion protection.

SUBSTANCES CAS NO. / EC NO. POTENTIAL APPLICATION

1ST SVHC CANDIDATE LIST (PUBLISHED ON 28 OCTOBER, 2008)

Lead hydrogen arsenate# 232-064-2 / 7784-40-9 Herbicides, insecticides

Benzyl butyl phthalate (BBP) 201-622-7 / 85-68-7Plasticizers, additive to adhesives or printing inks PVC Plasticizers, additive to adhesives or printing inks Plasticizer

Bis(2-ethyl(hexyl)phthalate) (DEHP) 204-211-0 / 117-81-7

Cobalt dichloride# 231-589-4 / 7646-79-9 Drying agents such as silica gel

Bis(tributyltin) oxide (TBTO) 200-268-0 / 56-35-9 Electrical and electronic products, textile, insulator

5-tert-butyl-2,4,6-trinitro-m-xylene (musk xylene)

201-329-4 / 81-15-2 Fragrance

Diarsenic trioxide# 215-481-4 / 1327-53-3Decolorant, glassware, wood preservatives, metallurgy

Triethyl arsenate 427-700-2 / 15606-95-8 IC

Diarsenic pentaoxide# 215-116-9 / 1303-28-2 Dyes, glassware, metallurgy

Sodium dichromate dehydrate#234-190-3 / 7789-12-0, 10588-01-9

Pigment, metal finishing, coloured glass and ceramic glazes

Dibutyl phthalate (DBP) 201-557-4 / 84-74-2 Plasticizers, additive to adhesives or printing inks PVC Plasticizers, additive to adhesives or printing inks Plasticizer

4,4'- Diaminodiphenylmethane (MDA) 202-974-4 / 101-77-9 Dyes

Alkanes, C10-13, chloro (Short Chain Chlorinated Paraffins) (SCCP)

287-476-5 / 85535-84-8 Flame retardants

Anthracene 204-371-1 / 120-12-7 Dyes

Hexabromocyclododecane (HBCDD)

247-148-4, 221-695-9 / 25637-99-4, 3194-55-6 (134237-50-6) (134237-51-7) (134237-52-8)

Flame retardants

21

The REACH Regulation is a very demanding legal framework for any business either large or small, which are directly or indirectly dealing with chemicals. Communication on SVHC is mandatory for any article marketed within the EU if the value exceeds 0.1% w/w. Since 2008, the Candidate List has been growing and there are 183 SVHCs up till now.

VII. CONCLUSIONThe E&E industry is facing a huge challenge due to the complexity of E&E products and frequent updates of the Candidate List. Compliance burden is very demanding for both testing and non-testing approach. There is an increasing demand of reasonable and cost effective approach to address SVHC compliance issue.

With our expertise in REACH SVHC service and experience in the E&E industry, our Smart SVHC solution service can help our clients to minimise the risk of non-compliance in an intelligent way.

Guidance on requirements for substances in articles:https://echa.europa.eu/documents/10162/23036412/articles_en.pdf/cc2e3f93-8391-4944-88e4-efed5fb5112c

SVHC Roadmap to 2020 Implementation Plan. https://echa.europa.eu/svhc-roadmap-to-2020-implementation

VIII. REFERENCESThe Consequences of REACH for SMEs. http://www.eesc.europa.eu/resources/docs/the-consequences-of-reach-for-smes.pdf

Report on the penalties applicable for infringement of the provisions of the REACH Regulation. http://ec.europa.eu/environment/chemicals/reach/enforcement_en.htm

http://www.eesc.europa.eu/resources/docs/the-consequences-of-reach-for-smes.pdf



http://ec.europa.eu/environment/chemicals/reach/enforcement_en.htm

http://ec.europa.eu/environment/chemicals/reach/enforcement_en.htm

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ABOUT THE AUTHORS

Dr. Jackson Woo, CBiol, MRSBBusiness Manager, Electrical and Electronics Technology, Consumer and RetailSGS Hong Kong Ltd

Jackson received his PhD in the field of Toxicology from the University of Hong Kong. He joined SGS Hong Kong in 2012 and worked as Technical Services Executive in the department of Electrical and Electronics Technology. He was promoted to Senior Technical Services Executive in 2013 and acted as the technical team leader for Electrical and Electronics Technology in Hong Kong. He also chaired the Risk Assessment Task Force for Global Restricted Substances Testing Services on E&E products. He is now the department head of Electrical and Electronics Technology in SGS Hong Kong.

Mr. Litto TamSenior Technical Services Executive, Electrical and Electronics Technology, Consumer and Retail SGS Hong Kong Ltd

Litto joined SGS Hong Kong in 2012 and worked as Chemist in the department of Electrical and Electronics Technology. In the meantime, he finished his postgraduate study of Analytical Chemistry in Hong Kong Baptist University. He acted as the leader of the operation team and was responsible for report reviewing. He was granted the SGS and various accreditation bodies’ approval signatory. In 2017, he rotated his duty as Technical Services Executive in technical team and promoted to senior Technical Services Executive in the same year. Litto is also a member of the CHK RSTS EE Technical Team.

Dr. Udo KrischkeGlobal Technical Manager RSTS & Operation Integrity Manager, Consumer and Retail, Global Competence Support Center SGS Germany GmbH

Udo Krischke studied chemistry and received his Doctorate in AtmosphericChemistry from Frankfurt University, Germany, in 1998. He joined SGS Institut Fresenius in 2000. He worked as project manager in the department of product testing and was promoted as deputy head in 2005. Since 2007 Udo has the position as Global Technical Manager for the Restricted Substance Testing Service of Consumer Testing Service of SGS and by 2010 joined the management team of SGS Global Competence Support Center. Since 2008 he contributes to the work of the SGS global REACH team. Within GCSC he chairs the Technical Committee for Food Contact Materials since 2012 and also acts as lead auditor for the QHSE cross border audit program since 2013. Udo joined the IEC standardisation committees on hazardous substances in EE products in 2007. Since 2008 he acts as convener of Expert Task Force 12 for the IECEE hazardous substance report service.

ABOUT SGS

SGS is the world’s leading inspection, verification, testing and certification company. SGS is recognised as the global benchmark for quality and integrity.

With more than 95,000 employees, SGS operates a network of over 2,400 offices and laboratories around the world.

Enhancing processes, systems and skills is fundamental to your ongoing success and sustained growth. We enable you to continuously improve, transforming your services and value chain by increasing performance, managing risks, better meeting stakeholder requirements and managing sustainability.

With a global presence, we have a history of successfully executing large-scale, complex international projects. Our people speak the language, understand the culture of the local market and operate globally in a consistent, reliable and effective manner.We have a harmonised approach to delivering services to our customers, leveraging the largest independent network of consumer product experts in the world.

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This White Paper is for informational purposes only. SGS makes no warranties, express, implied or statutory, as to the information in this document.

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