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Companies on how they use the SIN List

The EU chemicals regulation REACH provides consumers with the "right to know" whether a product contains hazardous substances. When BEUC, the European Consumer Organisation, recently tested this by approaching retailers and manufacturers with a ‘right to know' request, they received very few satisfactory answers. BEUC asked if any SIN List substances were present in their products, several companies answered stating that they use the SIN List in their toxic use reduction work and that their products do not contain any SIN List substances.

The REACH "right to know" (article 33) enables consumers to ask retailers and manufacturers if any of their products or packaging contain any Substances of Very High Concern (SVHC) which are listed on the REACH candidate list in a concentration higher than 0.1%. Relevant information, such as the substance name, must be provided, free of charge, within 45 days.

BEUC and its member organisations throughout Europe have tested this ‘right to know' tool by checking if companies are aware of these obligations and able to answer in a precise and consumer-friendly way within the timeline. They sent consumer letters from nine EU countries (Austria, Denmark, France, Germany, Greece, Poland, Spain, Sweden and the UK) asking retailers if a specific consumer product, representing 34 categories of products, contained any of the SVHCs on the REACH candidate list.

As a result of the 25 letters sent in each country, only ten satisfactory answers were received in Sweden and Austria, nine in Germany, eight in France, seven in UK, three in Poland and Denmark, and only one in Greece and none in Spain.

- Along with greater transparency, the intention of the REACH 'Right to Know' was to create pressure on industry to develop safer substitutes. Unfortunately, this right is far from respected. Improvements are urgently needed, comments Monique Goyens, BEUC Director General.

More encouraging is that in their answers, several companies state that they use the SIN List.

  • Mark and Spencer, UK: "The SIN List has been in existence since 2008, and is used by NGO's to put pressure on the European Chemicals Agency (ECHA) to include these chemicals in their SVHC list. There is no legal basis behind this list, however, it is one of a number of sources of information we refer to when drawing up lists of restricted substances that are relevant to Marks and Spencer products."
  • H&M, Austria: "The 'Chemical Restrictions' list of H&M exists since 1995 and is continuously being updated. One source of information for this list is the SIN List of the NGO ChemSec."
  • Stadium, Sweden: "We follow our chemical guide which is very strict and we continuously watch the SIN List and other similar lists from voluntary organizations."
  • Dänisches Bettenlager, Austria: "In this context, the SIN List which has now been enlarged by 22 substances to 378 chemical substances will continue to be in our focus."
  • Viking, Sweden: "We have also checked with our manufacturers, and they have checked with their suppliers and confirm that they do not use any chemicals included in the SIN List."

- The SIN List is now part of the horizon scanning of many European companies, and we are pleased to note that an increasing number of them actively use the SIN List in their work to identify and substitute the most hazardous chemicals, says Jerker Ligthart, ChemSec project coordinator.

BEUC report