of chemicals regulated in consumer and industrial products due to government regulation, industry standards, or customer requirements. An RSL aims to minimize or eliminate hazardous substances to make products safer and promote circularity. Companies may find it difficult to keep track of RSLs over time as new substances are added to preexisting lists and new regulations emerge. H2 Compliance provides a variety of services to help our clients identify restricted substances in their products and monitor substances proposed for future risk management.
Regulatory Drivers for Restricted Substances Lists
Regulatory Lists Under EU REACH
Various regulatory lists are implemented under EU REACH, such as:
- Annex XVII Restricted Substances List
- Annex XIV Authorisation List
- Substances of Very High Concern [SVHC] Candidate list for Authorisation.
These lists highlight substances which are currently subject to regulatory risk management actions across the European Union.
Several lists also address substances which have been proposed for future risk management action, such as:
- Assessment of regulatory needs list [RMOA List]
- Registry of restriction intentions until outcome [ROI Restriction List]
- Registry of SVHC intentions until outcome [ROI SVHC List]
These are early warning lists and can be monitored to help companies anticipate when new restrictions may enter into force. This helps organizations take advanced action to eliminate or substitute chemicals to stay ahead of future regulatory impacts.
Restricted Substances Lists in the US and Abroad
Other restricted substances lists include those in the United States, such as:
- US California Proposition 65 List
- Persistent, Bioaccumulative and Toxic [PBT] chemicals banned under Section 6[h] of the EPA’s Toxic Substances Control Act [TSCA]
- Substances identified under TSCA for risk evaluation and management.
Other lists like the Persistent Organic Pollutants [POPs] List under the Stockholm Convention place restrictions on hazardous chemicals at a global scale. Specific industry sectors such as textiles and toys have their own unique requirements and substance restrictions.
Restricted Substances in Articles
If you supply articles that contain SVHCs to the EU market, you may have responsibilities under REACH to notify authorities or downstream users. Products may also need to be notified to the Substances of Concern in Products [SCIP] database. If you manufacture or import electronic products or equipment, you may have further obligations under the Restriction of Hazardous Substances [RoHS] Directive. If you sell products into California, specific labelling obligations may apply if they contain substances listed on Prop 65 that can expose users above safety limits.
Establishing a structured restricted substances list tracking process for your products will allow you to visualize current and future risks so that you can maintain market access. Moving from a reactive to a proactive approach to compliance will ensure long-term business viability and success.
Achieving Compliance
Keeping track of the substances in your products and understanding if they are included on various restricted substances lists can be a challenging task. We can help reduce your business risk in the following ways:
- Identify substances of concern in your products through restricted substances list tracking.
- Carry out an impact assessment of your products to help prioritize action plans.
- Advise on a management system to ensure compliance.
- Carry out SCIP notifications and other product registrations.
- Perform exposure and toxicology risk assessments to assist in making Prop 65 product labelling decisions.
- Coordinate lab testing to identify the presence and concentration of restricted substances in your products.
Our software and service solutions delivered over our Element1 platform makes compliance easy by allowing you to:
- Utilize a central platform to store product composition data and view substance matches to a global portfolio of restricted substances lists.
- Use a visual interface to easily interpret risks on both a substance and product level.
- Evaluate product risks quickly when restricted substances lists are updated.
Restricted substances list tracking is one of the many ways we help our clients stay ahead of evolving regulatory requirements and industry trends. Please visit our Product Stewardship page to learn more about our tailored solutions and how we can help.
Contact Us Today
We are compliance and regulatory experts. Call us today to arrange a free 30 minute consultation.
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