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Obligation of Candidate List

  • Obligations about article suppliers under REACH in relation with SVHCs:

1-) Communication about SVHCs in the supply chain;

From the date of inclusion (which is 28 October 2008 for the first 15 substances), EU or EEA suppliers of articles which contain substances on the Candidate List in a concentration above 0.1% (w/w) have to provide sufficient information, available to them, to their customers or upon requests, to a consumer within 45 days of the receipt of the request. This information must ensure safe use of the article and as minimum contain the name of the substance.

Although REACH Regulation itself does not indicate any format of communications on substances in the articles, there is this following example format of communication in the supply chain about SVHCs in the articles in the ECHA's Guidance on requirements for substances in articles :

 

 Item  Example
 Substance Name  Diarsenic trioxide
 CAS Number   1327-53-3
 Registration Number (If provided by supplier)   01-1234567-49-00
 

Classification and SVHC properties

Carc. Cat. 1; R45; May cause cancer

T+; R28; Very toxic is swallowed

C; R34; Causes burns

N; R50/53; Very toxic to aquatic organisms, may cause longterm adverse effects in the aquatic environment.

Concentration in the article

 % 1 w/w 
 

Information on safe handling including safe disposal if relevant

Prevent from heating above 60 °C

Keep article out of reach of children

This article should be disposed of as hazardous waste. Do not dispose of via normal household waste.

  

2-) Obligation to notify ECHA about SVHCs in your articles;

EU and EEA producers or importers of articles have to notify ECHA if their article contains a substance on the Candidate List. This obligation applies if the substance is present above 0.1% (w/w) and its quantities in the produced/imported articles are above 1 tonne in total per year per company. So as an exporter you have right to choose to notify ECHA about AVHCs in your articles. To do so you should choose one of the ways that are described in our 'What is your role' page.

At ECHA's press release on 4th November 2008, the deadlines are like that:

  • For substances included in the Candidate List before 1 December 2010, the
    notifications have to be submitted not later than 1 June 2011.
  • For substances included in the Candidate List on or after 1 December 2010, the
    notifications have to be submitted no later than 6 months after the inclusion.

Note: A notification is not required when

  1. the producer or importer of an article can exclude exposure of humans andthe environment during the use and disposal of the article. In such cases,the producer or importer shall however supply appropriate instructions to the recipient of the article.
  2. The substance has already been registered for that use up the same supply chain or any other supply chain.

 

  • Obligations for suppliers of substances:

From the date of inclusion (which is 28 October 2008 for the first 15 substances) EU and EEA suppliers of substances on the Candidate List have to provide their customers with a safety data sheet.

  • Obligations for suppliers of preparations:

EU and EEA suppliers of preparations not classified as dangerous according to Directive 1999/45/EC have to provide the recipients, at their request, with a safety data sheet if the preparations contain at least one substance on the Candidate List
and its individual concentration is at least 0.1% (w/w) for non gaseous preparations and at least 0.2% by volume for gaseous preparations.

The specific provisions on obligations linked to the substances on the Candidate List of Substances of Very High Concern can be found in the REACH Regulation as follows:
• Art. 7.2 – Notification to ECHA
• Art. 7.3 – Supply of appropriate instructions
• Art. 31.1 – Provision of Safety Data Sheet
• Art. 33 – Duty to communicate safe use information or responding to customer requests

International Chemical Secretariat (chemsec) together with some other NGOs has come with a list of 267 hazardous  substances that may be in the SVHC Candidatle List of REACH. This list is called as sinlist (Substitute It Now). Although this is  not an official list under REACH, some industry members see the list as an 'indicator' and may ask their suppliers to avoid using those substances in the (sin)list. You may find more information and the whole list at www.sinlist.org.         

Legal notice

This page contains the guidance for completing the legal requirements. The only reliable source of law is the legislation itself. This site does not hold constituents for legal advice. IMMIB does not accept any legal reponsibility for the content of this site.

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