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Notification Deadline Looms for Certain Substances Found in, Among Others, Gloves, Leather and Textile Articles

On 25 May 2016, the European Chemicals Agency (ECHA) warned in an announcement addressed to companies that a deadline concerning substances in articles is fast approaching. ECHA has stated that, by 17 June 2016, suppliers must submit notifications of five substances of very high concern (SVHCs) that were added to the so-called Candidate List in December 2015.

Hong Kong suppliers of any articles that contain one or more of the five substances in concentrations greater than 0.1% should inform their downstream suppliers of any available safety information on the substance(s) concerned. The obligation applies to articles manufactured in or imported into the EU. The substances, and their (non-exhaustive) uses, are as follows:

  • Perfluorononan-1-oic-acid and its sodium and ammonium salts (PFNA and its salts) (EC 206-801-3; CAS 375-95-1, 21049-39-8, 4149-60-4). This substance and its salts may be the most relevant to Hong Kong suppliers, as they can be found in gloves, leather, paper-based food contact materials, liquid crystal display (LCD) panels and textiles. They are used in the production of these articles as, for example, cleaning agents, textile antifouling finishing agents, polishing surfactants and waterproofing agents.
  • 1,3-propanesultone (EC 214-317-9; CAS 1120-71-4): This substance may be found in lithium-ion batteries as electrolyte fluid additive.
  • 2,4-di-tert-butyl-6-(5-chlorobenzotriazol-2-yl)phenol (UV-327) (EC 223-383-8; CAS 3864-99-1). This substance may be found in surface coatings, plastics and rubber as UV-protection agents.
  • 2-(2H-benzotriazol-2-yl)-4-(tert-butyl)-6-(sec-butyl)phenol (UV-350) (EC 253-037-1; CAS 36437-37-3). This substance may be found in surface coatings, plastics and rubber as UV-protection agents.
  • Nitrobenzene (EC 202-716-0; CAS 98-95-3). This substance may be found in dyes and synthetic rubber.

Hong Kong businesses exporting articles to EU customers should check to see if their articles contain any of the substances mentioned above, and if so, to ensure that a notification is submitted accordingly (the legal provision is set out in Article 7 of the REACH Regulation and is imposed on EU manufacturers and importers of the goods). ECHA has stated that notifications can be submitted through the “substance in article” web form, or through its REACH-IT using IUCLID.

To recap, EU producers and importers have to notify the substances listed on the Candidate list which are present in their articles, if both the following conditions are met:

(i) the substance is present in their relevant articles above a concentration of 0.1%; and
(ii) the substance is present in these articles in quantities totaling over one tonne per year.

Companies have to notify no later than six months after the inclusion of the substance in the Candidate List.

There are only two situations when a notification will not be required: one is that the producer or importer of an article can exclude the exposure of humans and the environment to the substance during normal or reasonably foreseeable conditions of use of the article, including its disposal. In this situation, appropriate instructions have to be provided to the recipient of the article. The second is that the substance has already been registered by a (any) manufacturer or importer in the EU for that use.

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