ECHA Propose to Add 18 Substances to REACH Annex XIV

Substances of Very High Concern in the Candidate List are regularly considered for addition to Annex XIV. If a substance is included in Annex XIV, it cannot be used, after the “sunset date”, in the EU unless the chemical process has been authorised by the EU. Obtaining authorisation is not straightforward, requires a great deal of effort and can be a very expensive process. Therefore manufacturers will request authorisation for these substances only if there are no alternatives and future income from continued use is sufficient to justify authorisation costs. It has been common in the past for manufacturers to stop sales of Annex XIV substances in the EU, forcing users to find alternatives. The current proposed 18 substances, published on 5th September 20181, include many that are used in large quantities in the EU and may be difficult to substitute. These are:

• Bisphenol A – used to make epoxy resins, polycarbonate and many other polymers, adhesives and paints.
• Dechlorane Plus – a very widely used flame retardant used in many types of polymer and also in adhesives.
• Reaction products of 1,3,4-thiadiazolidine-2,5-dithione, formaldehyde and 4-heptylphenol, branched and linear (RP-HP) with ≥0.1% w/w 4-heptylphenol, branched and linear (4-Hbl) – additive in lubricants and grease.
• 2-ethylhexyl 10-ethyl-4,4-dioctyl-7-oxo-8-oxa-3,5-dithia-4-stannatetradecanoate (DOTE) and Reaction mass of 2-ethylhexyl 10-ethyl-4,4-dioctyl-7-oxo-8-oxa-3,5-dithia-4-stannatetradecanoate and 2-ethylhexyl 10-ethyl-4-[[2-[(2-ethylhexyl)oxy]-2-oxoethyl]thio]-4-octyl-7-oxo-8-oxa-3,5-dithia-4-stannatetradecanoate (reaction mass of DOTE and MOTE) – polymer stabilisers, whose main use is in PVC.
• 4,4′-bis(dimethylamino)-4”-(methylamino)trityl alcohol with ≥ 0.1% of Michler’s ketone or Michler’s base – used in printing and writing inks (this may also be called Solvent Violet 8). It may also occur in polymers.
• Seven lead compounds – Dioxobis(stearato)trilead, fatty acids, C16-18, lead salts, trilead dioxide phosphonate, sulfurous acid, lead salt, dibasic, [Phthalato(2-)]dioxotrilead, trilead bis(carbonate) dihydroxide and lead oxide sulphate. These are mainly used as PVC stabilisers (although would not be RoHS compliant if used), the carbonate is a white pigment used in artists paints and some are also used for making mirrors.
• Cyclohexane-1,2-dicarboxylic anhydride and hexahydromethylphthalic anhydride are hardeners or curing agents for adhesives and coatings, especially for epoxy resins. Anhydride hardeners give specific performance to epoxy resins which are different to other types of hardeners.
• Tetraethyllead – fuel antiknock agent banned in road vehicles, but still used in some types of aircraft fuels.
• 2-Methoxyethanol and 2-ethoxyethanol are both used as solvents. Uses include aircraft fuel de-icing, solvent for cellulose acetate and other resins, dyes, paints, inks, varnishes, enamels, nail polishes and wood stains. These are widely used in the semiconductor industry and also as process chemicals to make other substances.

A public stakeholder consultation is being held and closes on the 5th December 2018. These additions would bring the number of entries in Annex XIV to 61.

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