The SIN List is a comprehensive list of substances that has been identified by ChemSec as fulfilling the criteria for Substances of Very High Concern (SVHC), as described in the EU chemicals regulation REACH article 57. Three categories are included in REACH article 57, and the SIN List encompasses substances from these three categories.
1. The first category is chemicals that can cause cancer, alter DNA or damage reproductive systems. These are called CMR substances (Carcinogenic, Mutagenic or Toxic to reproduction.)
2. Then there are harmful substances that do not easily break down and accumulate in the food chain. These are known as PBT substances (short for Persistent, Bio-accumulative and Toxic). There is also the abbreviation vPvB, short for very Persistent and very Bio-accumulative.
3. The third category is called “substances of equivalent concern”. This category covers substances that are not automatically covered by the other two categories, but which nonetheless give rise to equivalent level of concern in terms of potential damage to health and environment. This category e.g. includes endocrine disrupting chemicals.
General principles used for the compilation of the SIN List
All substances on the SIN List have been screened to identify substances covered by the authorisation provisions in REACH. Substances exempt or otherwise not regulated by REACH, such as pesticides, intermediates and unintentionally produced substances, have accordingly been removed.
All information used for selection and assessment of substances for the SIN List is publicly available. For CMRs the official CLP (Classification, Labelling and Packaging) classification has been used. These substances have been agreed on a EU-wide basis to have properties corresponding to the SVHC criteria.
PBT and vPvB chemicals for the first version of the SIN List were added directly from the European PBT Working Group List which was developed by the former European Chemicals Bureau (ECB), which duties have since been taken over by ECHA .
Equivalent level of concern substances (REACH article 57f) added to the SIN List have undergone a more in-depth scientific evaluation and case-by-case assessment, based on publicly available peer-reviewed scientific studies. This has also been the case for evaluation of PBTs/vPvBs in 2014.
Exclusive rather than inclusive
It should be clearly stated that the absence of the substance on the SIN List does not indicate that this is a non-hazardous chemical. There are several reasons for why a substance has not been added: it was never present in the “starting material” for an update (typically other priority lists, reports and review studies) or it was assessed but there was at the time not enough available data to include it on the SIN List. Therefore the SIN List should not be considered as a final list, but rather an important first step towards a more comprehensive list of SVHCs in need of regulation.
For details on the inclusion of substances on the SIN List, please do consult the methodology document.