According to ECHA’s SVHC Roadmap to 2020 Implementation plan, ECHA is committed to have “all relevant currently known SVHCs included in the candidate list by 2020”. The candidate list includes substances that can be recommended for inclusion in the Authorisation list ( REACH Annex XIV).
This said, companies with SVHC substances are advised to take a proactive approach to influence on the outcome of their business, by having a well maintained inventory of the substances they manufacture, use or import, to screen their SVHCs and determine their importance on their business. After that, companies will be ready to start preparing an adequate business strategy towards authorisation.
As the candidate list is updated twice per year, it is important for companies to monitor ECHA’s website and check whether their SVHCs have been included or not on the candidate list.
Our Advocacy Services
At REACHLaw, we support your company to create a proper authorisation strategy by assessing the relevance of your SVHCs for your business and by analyzing the risks associated to them. Also, we help you to meassure the impacts of the SVHCs not only in your company, but also in the economy and in your business sector.
Furthermore, REACHLaw supports you with the Public consultations and RMOA phases by providing the right information, at the right time, to the right counter-parties and with the right strategy. In fact, REACHLaw has been strategic advisor for a number of advocacy projects.
Companies with REACH Annex XIV substances in their product portfolio, aiming to continue doing business in the EU -after the so called “sunset date”- need to prove that the risks associated with the use of these substances are properly controlled or that the socio-economic benefits from their use outweight their risks. At the same time, companies need to start thinking on substitution possibilities as one of the Authorisation aims is to replace those substances for suitable alternatives where these are technically and economically viable.
Who can apply for authorisation?
Manufacturers, importers and downstream users can apply an hold authorisations for their own uses or for uses down their supply chain. It is important to note that the rules regarding who can can be the authorisation holder may have the potential to cause supply disruptions if there are missing links along the supply chain.
What makes an application succesful?
An authorisation application is a matter of how convicing the argumentation presented in your application is. Your company will need to have enough resources and expertise in-house to be able to compile all the required information in a clear and convincing way, to be presented to all the ECHA Committees for making their opinions, and for the European Commission (EC) to make its decision on granting or not an authorisation for the use(s) you have applied for.
Whether you are a manufacturer, importer or a downstream user, you may have obligations under REACH if your substances are on the candidate list.
- “EU or EEA suppliers of articles containing substances on the candidate list in a concentration above 0.1% (w/w) have to provide enough information for safe use on the article to the consumers or upon request.
- From 2011, manufactures or importers of articles have to notify to ECHA if their article contains a substance on the candidate list, if the substance is present in the article in quantities over one tonne per year and if it is present in concentrations above 0.1% (w/w).
- Suppliers of candidate list substances have to provide to their customers with a SDS and suppliers of mixtures containing substances on the candidate list will need to provide with a safety data sheet if the individual concentration of the substance in the mixture is > 0.1% (w/w)”.
More information at: https://echa.europa.eu/candidate-list-obligations
Don’t know how to fulfill your obligations?
At REACHLaw we help you with the notification of your substances and we advise you on how to fulfill the communication obligations along your supply chain.
REACHLaw has a vast experience on authorisation applications not only because of the significant number of applications successfully submitted to ECHA, but also because of the outcome obtained, as our customers have received 12 years of review periods.
Our experience goes from upstream applications to joint downstream users application and individual downstream users applications. Thanks to our multidisciplinary team of experts we can offer companies a one-stop shop service for authorisation, to successfully prepare all the key elements of the authorisation application such as: SEA ( Socio-Economic Analysis), AoA ( Analysis of Alternatives) and the CSR ( Chemical safety Report).
But this is not all yet, as we also offer post-submission support. We have worked with many RAC ( Committee of Risk Assessment) and SEAC ( Socio-Economic Analysis Committee) members on past and current projects, which allows us to offer a complete service for our customers. As an example, we have prepared applications for European Space cluster companies as well as for APEAL companies.
Would you like to know more about our support? Kindly, click here