SUBSTANCES OF VERY HIGH CONCERN

European Union’s Candidate List

As of 2006, the European Union has a chemical regulation called REACH which stands for Registration, Evaluation, Authorisation and Restriction of Chemicals. Alongside REACH it was also established a regulatory authority called The European Chemicals Agency, in short ECHA. It’s ECHA that does the “legwork” by managing the administrative, scientific, and technical aspects of REACH.

Part of ECHA’s work includes gathering particularly harmful substances, Substances of Very High Concern (SVHC), in something called the Candidate List. It is called the Candidate List as it refers to that all substances put on the list are candidates to end up on (yet another list) called the “REACH authorization list”. Substances on the latter list are not allowed to be sold or used in the European Union after a given date, which they poetically call the “Sunset date”, unless specific authorization is granted. But for a substance to first be able to qualify as a SVHC, there needs to be strong scientific evidence that it is unsafe for humans or has a negative effect on the environment.

Substances causing serious and lasting effects

Substances of Very High Concern are not automatically banned or restricted. The listing is a first step toward banning or restricting; the substance could have specific requirements to be allowed on the market or it can simply be viewed as a “warning” that assessment is ongoing. The cosmetic industry is one among many industries that affected by these regulations as there are cosmetic products containing SVHC.

There are certain criteria that need to be met for a substance to be included on the Substance of Very High Concern list, but even then are not all substance proposals approved. In general, for a substance to be classified as being of very high concern it should cause serious and lasting effects on human health and the environment. Common causes for SVHC classification of ingredients that are found in cosmetic products, is that they are carcinogenic, toxic for reproduction, or toxic for aquatic life.

Some of the criteria and properties the substances should show are:

  • CMR substances  Carcinogenic, Mutagenic or Toxic for reproduction

  • PBT substances – Persistent (don’t break down easily in nature), Bioaccumulating and Toxic

  • vPvB substances – Very persistent and very bioaccumulative

  • Case by case – Identified on a case-by-case basis where scientific evidence show probable serious effects that cause equivalent level of concern as the above mentioned. Endocrine disrupting chemicals for example.  

It is difficult to know just how many substances that exist in the world today, but one estimation comes from the American Chemical Society (CAS); they have listed more than 135 million unique chemical substances in their database.

Out of the possibly more than 135 million substances that exist in the world there are only 181 substances on the Candidate List. 43 of those substances are on REACH authorization list (as of January 2018).

From this perspective it‘s evident that these chemicals, classified as “Substances of Very High Concern”, are a group of carefully selected few.

On ECHA’s website, one can read that REACH “has been described as the most complex legislation in the Union’s history and the most important in 20 years. It’s the strictest law to date regulating chemical substances and will affect industries throughout the world.”

Critiques, on the other hand, argue that ECHA is moving to slow and that the laws, even though being the strictest in the world, are not strict enough and should in fact include more prohibitions and restrictions.

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