Three Proposed Additions to REACH Candidate List

The European Chemicals Agency (ECHA) has proposed three Substances of Very High Concern (SVHC) for possible addition to the REACH Candidate List. The substances and their main uses are:

• Dibutylbis(pentane-2,4-dionato-O,O’)tin (EC 245-152-0, CAS 22673-19-4) – used as a catalyst in adhesives (such as for bonding PVC), paints, lacquers and sealants. This compound is not consumed when used as a catalyst so will be present in articles. It is usually used in the concentration range typically of 0.1 to 1%, but some formulations contain up to 10%. 
• 2-Methylimidazole (EC 211-765-7, CAS 693-98-1) – used as a dyeing additive for acrylic fibers and in polymer foams, as a curing agent for epoxy resins, printed circuit board laminates, and in various adhesives and for encapsulation. It is used as an accelerator in polymeric coatings of food packaging and is also a process chemical used to synthesize antibiotics. 2-Methylimidazole is consumed when used as a dye additive, in foams and as a curing agent and as an accelerator so should not occur in articles. 
• 1-Vinylimidazole (EC 214-012-0, CAS 1072-63-5) – Reactive additive used to make UV lacquers, inks and adhesives for coatings and lacquers (so is not present in cured materials). It is also used as a process chemical to make a wide variety of other substances. 

The next step will be to determine whether these substances meet the criteria of Article 57 of REACH. ECHA do not consider whether these should or should not be added to the Candidate List for any other reasons, such as the impact on EU competitiveness, etc. Inclusion of the two imidazole compounds in the Candidate List should not trigger Article 33 declarations as these substances are not present in articles, however were they to be eventually included in Annex XIV it would be a serious issue for many different industry sectors that use these substances and by-products made using this substance.