In an article published on November 16, 2017, the non-governmental organization International Chemical Secretariat (ChemSec) responded to the analysis of its SIN List carried out by the European Chemicals Agency (ECHA) and discussed in ECHA’s article published on the same day.

ECHA’s analysis concluded that most of the substances on the SIN List “are regulated or under scrutiny, but more work needs to be done.” ChemSec welcomed “the recognition of the SIN List as an important source of information for ECHA,” and strongly agreed “with the notion that more work needs to be done.” ChemSec, however, expressed a concern “that the analysis may give a false impression that the use of SIN List chemicals in the EU is under control.”

ChemSec commented that the “SIN List aims to identify SVHCs [(substances of very high concern)] of relevance for the Candidate List.” Currently, the SIN List contains over 900 substances, but the REACH Candidate List for authorization contains less than 200. Therefore, ChemSec called on EU Member States and ECHA “to accelerate the process [of adding substances on the Candidate List],” warning that “the political target of having all known relevant SVHCs listed by 2020 is not likely to be met.”

Frida Hök, senior policy advisor at ChemSec, explained that having substances listed on the Candidate List “is crucial as this is such a strong driver for substitution and is followed by the right to know about hazardous chemicals in products.” Hök further said that “ChemSec is convinced that every substance on the SIN List fulfils the criteria for identification as an SVHC . . . and should therefore be placed on the Candidate List.” She further stated that the prioritization approach currently followed by ECHA “might lead to . . . hazardous and important substances . . . [being] overlooked,” and pointed out that “the substances identified by ECHA as being under ‘regulatory scrutiny’ are likely many years from being regulated if these processes continue at the current speed.”

Read more

ChemSec (November 16, 2017). “All SIN List chemicals belong on the Candidate List.

ECHA (October 24, 2017). “Analysis of the SIN List.(pdf)

Adam Elwan (November 16, 2017). “How are SIN List substances being addressed?ECHA Newsletter

ChemWatch (November 22, 2017). “Echa finds unregulated substances on ChemSec SIN List.