SVHCs on candidate list
A substance which is an SVHC on candidate list, but which is not Authorised triggers certain obligations for hazard communication.
SVHCs on candidate list – placing substance or mixture on the market
An SVHC substance, or a substance with SVHC impurity, or mixture containing SVHC component:
- even if not classified for CLP, still requires SDS at 0.1% w/w of SVHC as impurity or component (on request)
- section 3 of the SDS must include the SVHC substance name, i.d. nos, hazard classification (if any) etc but there is no requirement to formally identify it as being an SVHC (although this is considered good practice)
- there does not appear to be a requirement to identify an SVHC impurity or component substance on the CLP label
SVHCs on candidate list – downstream user
If you receive a product which is an SVHC or contains one or more SVHCs at or above 0.1% w/w concentration, you should receive an SDS, whether or not the product is hazardous.
You do not have to make any changes to how you use or handle the product. However, if the SVHC is going through assessment, it may be prudent to look at whether you can remove it or substitute it. This is because the point of the Authorisation process is to remove substances from the EU marketplace entirely, unlike restriction, where the point is usually to allow substances to be used under conditions which will reduce the risk to humans and/or the environment across the EU.
You are obliged to provide, on request, an SDS for any mixtures you make containing one or more SVHCs at or above 0.1% w/w concentration .
SVHCs in articles
In certain circumstances, you may be required to notify ECHA for any articles you make or import contain an SVHC on the candidate list at or above 0.1% w/w, see https://ttenvironmenta.wpengine.com/clp-knowledgebase/articles-containing-clp-products/ for details.