REACH into 2022 with Full Material Disclosure

Feb 10, 2022 4:07:28 PM

Materials Health, Product Compliance

Are you prepared for REACH compliance in 2022? Here's a look at tips from Toxnot experts on managing your compliance, understanding what the newest chemicals are on the candidate list updates in 2022, and why they matter to you.

 

Are you prepared to report on REACH compliance for the upcoming year?

 

Top tips from Toxnot experts include:

  1. Stay up-to-date with your product and material records by storing full material disclosure in your Toxnot account.
    • Full material disclosure means that you have access to 100% of your product or material chemistry down to 100 or 1000 ppm. If you have this Bill of Material (BOM) information stored in Toxnot, it will be a fluent process to automatically screen your library for chemical additions or removals when regulations change.
  2. Send out recurring surveys to all of your suppliers to ensure that product and material records are ready to screen before regulations change.
    • This proactive work will ensure that you will always be one step ahead.
    • Toxnot allows manufacturers and suppliers to send out supplier surveys requesting information about topics such as circularity, sustainability, compliance, and document collection at the click of a button.
    • Toxnot surveys can be prefilled for suppliers by utilizing results from the previous year so that it is less work for them to respond to your requests.
  3. Maximize your participation in the Toxnot Exchange to obtain accurate and complete data.
    • The Toxnot Exchange allows users to easily share product passports across a public platform the allow seamless transmission of data between suppliers and manufacturers.
  4. Utilize Toxnot’s automatic compliance screening capabilities to ensure that your product library is still performing how you would expect it to, year after year.
    • Toxnot’s portfolio analytics even allow you to view your entire library of products and materials in one screen to easily located which products are not compliant with regulatory lists and standards.
    • Pinpoint the exact material or substance within your product that is holding it back from meeting compliance standards and take actions to update formulations if necessary.

 

What are the new chemicals on the REACH Candidate List in 2022 and will this impact you?

 

When did the REACH Candidate List change and who should be aware of this update?

The REACH Candidate List now has 223 chemical substances on it and is updated in Toxnot to serve your compliance needs. As of January 17, 2022, importers, producers, and suppliers will all need to respond to the addition of 4 new chemical substances that are deemed as being of high concern. Appropriate measures will need to be taken including:

  • Supplying a safety data sheet
  • Communicating on safe use
  • Notifying ECHA if the article you produce contains an SVHC (substance of very high concern) above 1 tonne per producer/importer per year and if the substance is present in articles above 0.1% weight-for-weight.

 

What are the four new chemicals on the REACH Candidate List?

Chemical Substance CAS # Why added? Chemical Substance
6,6'-di-tert-butyl-2,2'-methylenedi-p-cresol 119-47-1 Toxic for reproduction Rubbers, lubricants, adhesives, inks, fuels
tris(2-methoxyethoxy)vinylsilane 1067-53-4 Toxic for reproduction Rubbers, plastics, sealants
(±)-1,7,7-trimethyl-3-[(4-methylphenyl)methylene]bicyclo[2.2.1]heptan-2-one covering any of the individual isomers and/or combinations thereof (4-MBC)   Endocrine disrupting properties Cosmetics
S-(tricyclo(5.2.1.02,6)deca-3-en-8(or 9)-yl O-(isopropyl or isobutyl or 2-ethylhexyl) O-(isopropyl or isobutyl or 2-ethylhexyl) phosphorodithioate 255881-94-8 PBT Lubricants, greases

 

 

How do I inform EACH (European Chemicals Agency) if my articles contain SVHCs on the Candidate List above 0.1% weight by weight?

SCIP is a database for information on substances of concern in articles and it is established under the Waste Framework Directive (WFD). If it is determined that your article contains an SVHC over the limit, you can directly submit this information to the SCIP database using Toxnot. Easily access the REACH compliance page in your material record and directly submit to the database by linking your ECHA account to Toxnot. Click here to learn more about this process.

 

Why and how were these chemicals added to the REACH Candidate List?

  1. Substances are proposed as potential SVHCs (substances of very high concern) prior to submission to inform interested parties in advance
  2. Data and justification for identifying these as SVHCs is submitted
  3. Volume in the EU market, use cases for the chemical, and alternatives are evaluated
  4. The additional chemicals are published for interested parties to review for 45 days of consultation
  5. If nobody rejects the addition, it will be added to the list. If people go against the notion, the proposal will be passed along to the Member State Committee or to the Commission for further review and voting

 

Will the REACH Candidate List or other regulatory lists be changing again?

Yes! Get ahead of the game by importing your product and material library into Toxnot, filling in gaps utilizing supplier surveys, simulating compliance responses, generating compliance reports for your customers, and analyzing your product library through portfolio analytics!

 

 

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