On November 14, 2019, the non-governmental organization ChemSec announced that it has updated its Substitute It Now (SIN) List to include 47 additional chemicals and groups of chemicals, including those recognized for the first time as being persistent, mobile, and toxic (PMT) as well as carbon nanotubes. 16 of the substances were added for having PMT properties, 16 for being persistent, bio accumulative, and toxic (PBT), and 14 for being carcinogenic, mutagenic, or reprotoxic (CMR). Carbon nanotubes (CAS 308068-56-6) were added for being carcinogenic, persistent, and probably toxic to reproduction. Of the new chemicals added, the following are included within the FACET inventory of food contact chemicals:

  • 4-(1-methyl-1-phenylethyl)-N-[4-(1-methyl-1-phenylethyl)phenyl]aniline (CAS 10081-67-1)
  • 2,2′-methylenebis[6-(2H-benzotriazol-2-yl)-4-(1,1,3,3-tetramethylbutyl)-phenol (UV-360) (CAS 103597-45-1)
  • 1-vinylimidazole (CAS 1072-63-5)
  • melamine (CAS 108-78-1)
  • 1,4,5,6,7,7-hexachloro-8,9,10-trinorborn-5-ene-2,3-dicarboxylic anhydride (PE1+) (CAS 115-27-5)
  • 2-benzyl-2-dimethylamino-4′- morpholinobutyrophenone (CAS 119313-12-1)
  • 1,2-dihydroxybenzene (CAS 120-80-9)
  • 1,4-dioxane (CAS 123-91-1)
  • 2,2′-azobis[2-methylbutyronitrile] (AMB) (CAS 13472-08-7)
  • 2-(2H-benzotriazol-2-yl)-4-(1,1,3,3-tetramethylbutyl)phenol (UV-329) (CAS 3147-75-9)
  • N-butylbenzenesulphonamide (CAS 3622-84-2)
  • perfluorobutane sulfonic acid (PFBS) (CAS 375-73-5)
  • 3,3′-(1,4-phenylenediimino)bis[4,5,6,7-tetrachloro-1H-isoindol-1-one] (Pigment Yellow 110) (CAS 5590-18-1)
  • 2,2,4,4-tetramethyl-7-oxa-3,20-diazadispiro[]-henicosan-21-one (ODHO) (CAS 64338-16-5)
  • benzenamine, N-phenyl-, reaction products with 2,4,4-trimethylpentene (BPTMP) (CAS 68411-46-1)
  • 2-methylimidazole (CAS 693-98-1)
  • 2-(2H-benzotriazol-2-yl)-4,6-bis(1-methyl-1-phenylethyl)phenol (UV-234) (CAS 70321-86-7)
  • 2,5-thiophenediylbis(5-tert-butyl-1,3-benzoxazole) (Uvitex OB) (CAS 7128-64-5)
  • acetaldehyde (CAS 75-07-0)
  • 2,2′-dimethyl-2,2′-azodipropiononitrile (APN) (CAS 78-67-1)

On the same day, ChemSec held an event in Brussels, Belgium (FPF reported) to announce the update and provide a platform for stakeholders to learn about the new SIN List chemicals and discuss how to clean up the circular economy. The event was opened with presentations from European Parliament member Jutta Paulus, the Director of DG Environment of the European Commission, Kestutis Sadauskas, and Senior Program Manager from UN Environment, Jacqueline Alvarez. Key academic scientists involved in the review and selection of the chemicals added to the list also presented on the methodologies used. In the afternoon, representatives from industry presented on their efforts to substitute hazardous chemicals within their businesses, including Charlene Wall Waren from Apple, Sjoerd Dijkstra from DSM, and Malene Teller Blume from COOP Denmark. Photos from the event have been published, as well as the recorded presentations. A new promotional video for the SIN List was released.

Commenting on this update, Anne-Sofie Bäckar, Executive Director at ChemSec said “I believe companies and others will find it helpful to have a shortlist of PMTs [and] to have a bit more guidance regarding nanomaterials. Manufacturers of these chemicals may, of course, be worried that this will affect their sales and will argue against, for example, the need for PMT criteria. However, the same companies will, most likely, have initiated production of alternatives and by quickly marketing those there may even be market shares to gain.”

Read More

ChemSec (November 14, 2019). “Press Release: New chemicals on the SIN List challenge the global supply chain.”

Chemical Watch (November 14, 2019). “ChemSec adds PFASs, nanomaterial to SIN List.”

Anna Lennquist (January 14, 2020). “NGO Platform: SIN List adds PMTs and a first nanomaterial.” Chemical Watch

ChemSec (May 5, 2020). “Some researchers have criticised ChemSec for putting carbon nanotubes on the SIN List; here’s our response.”