What is the SIN List?
The SIN List is short for “Substitute It Now!” and consists of chemicals that ChemSec has identified as fulfilling the criteria for “Substances of Very High Concern” as defined by the EU chemicals regulation REACH. The list is based on credible, publicly available information from existing databases and scientific studies, as well as new research.
The aim of the SIN List is to spark innovation towards products without hazardous chemicals by speeding up legislative processes and giving guidance to companies and other actors on which chemicals to start substituting. The SIN List is a known and used tool for chemicals management globally. The European Commission has stated that the SIN List is a major driver for innovation, and the United Nations Environment Programme has highlighted the SIN List as a useful tool for chemical hazard assessment and chemical and product prioritisation.
Who has developed the SIN List?
The SIN List has been developed by ChemSec, a non-profit organisation working to substantially reduce the use of hazardous chemicals and its impact on health and the environment. ChemSec was founded in 2002 by environmental organisations and is funded by grants from authorities and foundations.
The development of the SIN List has been carried out in close collaboration with scientists and technical experts and guided by an NGO advisory committee of leading environmental, health, women and consumer organisations mainly in Europe but also in the US.
What is the connection between the SIN List and the EU chemicals regulation REACH?
Within the EU chemicals regulation REACH the most hazardous chemicals are defined as Substances of Very High Concern. EU member states have decided that the use of these substances should be strictly limited. However, the process of actually regulating specific chemicals within the scope of REACH has up until now been far too slow. We have a legislative framework in place, and it is about time to really make it work. This is what the SIN List is all about.
The SIN List consists of chemicals that have been identified by environmental NGO ChemSec as being Substances of Very High Concern, based on the criteria for these defined within REACH article 57.
What are Substances of Very High Concern?
The criteria for Substances of Very High Concern (SVHC) are described in REACH article 57. Three categories are included there, and also the SIN List encompasses substances from these three categories.
- 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.)
- Then there are substances that cause problems on the longer time scale – toxic substances that do not easily break down but rather 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.
- The third category is called “substances of equivalent level of 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. This category includes e.g. endocrine disrupting chemicals.
Why is the SIN List continuously updated?
Over time, new information on the hazardous properties becomes available. The political discussions and the interpretation of REACH criteria can also be slightly modified over time. In order to keep the SIN List up-to-date with the developments, regular updates are needed.
Why are the substances on the SIN List grouped?
The aim of dividing the SIN List into groups is to make the SIN List an even more user-friendly, hands-on tool for progressive chemicals management. The grouping of the SIN List also creates the foundation for the SINimilarity tool.
Why have you not included other types of substances on the SIN List, such as sensitizers or nanomaterials, which are highly relevant?
We do agree that these chemicals can be very relevant for the REACH candidate list, and not having included them specifically does not mean that we do not consider them important. Early in the process we considered having also such substances evaluated, but needed to prioritize. For example we saw a need to address more PBTs that have been used as substitutes e.g. for well-known POPs (Persistent Organic Pollutants).
Many SIN substances have not even been registered – how can you say that they are relevant?
It is very difficult for anyone not having access to industry data to judge how a substance is being used. There are several good reasons to look at non-registered substances as well:
- Not all substances have yet been registered. Many hazardous substances could in fact be among the low volume chemicals.
- Hazardous substances that are not registered could still be imported into the EU through articles.
- By addressing these chemicals we assure that they will not be used in the future.
- There may be substances that are used, although they have not been properly registered. E.g. it has earlier been shown that many substances registered as intermediates should have in fact been fully registered.
How could you identify endocrine disrupting chemicals when no official criteria are in place?
We can only regret that the process of developing EDC criteria has been much delayed. It is, however, still possible to identify EDCs, and to include them on the REACH candidate list under the SVHC category ”equivalent level of concern”. This has already been done for a number of substances. In the absence of EDC criteria we have identified the best available science and used a case-by-case approach. For this we have considered especially the endocrine mode of action, probable serious effects and a plausible link between the two.
What data have you used to identify PBT substances?
We have used the best available scientific expertise to assess these properties. The P, B and T properties have been identified using a weight of evidence approach including experimental data, estimated/modelled data, read-across to structurally similar substances and the properties of the degradation products.
Where can I find which scientific studies are used for the SIN List?
You cannot find the scientific references for each substance in the SIN List database, but if you send us an email, we are happy to forward the background data for the substances you are interested in. Please note that for substances having allready an official classification as being CMR – this is enough for inclusion on the SIN List and we do not have additional background data.
How can I use the SIN List?
- Many companies use the SIN List as a hands-on instrument to identify chemicals to substitute ahead of legislation, an important part of producing and selling safer and more sustainable products.
- Investors and financial analysts are using the SIN List to avoid investing in companies producing substances likely to be banned, and the financial risk that it implies.
- Regulators and authorities use the SIN List in the EU but also beyond, it is for example used as a source of inspiration in legislative processes in the US and Asia.
- Health, environmental and consumer NGOs are using the SIN List as a campaign tool when prioritizing individual chemicals or groups of chemicals for campaigning for safer products and stronger chemicals regulations.
What is SINimilarity?
SINimilarity is a new tool to make it easier to avoid non-sustainable and regrettable substitution. When using our online search function and searching for a substance that is not on the SIN List, you can find out how similar it is to the substances on the SIN List. This is now possible for about 500,000 substances. For substances that are similar to those already on the SIN List in terms of structure and function we recommend further investigations before use.
What kind of results do I get when searching the SINimilarity tool?
You will find out whether the substance you have searched for contains the same group specific structural elements as SIN substances and/or if it has structural similarity to SIN substances.
What are the limitations of the SINimilarity tool?
The SIN groups “Petroleum” and “Mineral fibres” contain substances of very complex chemical composition. Substances in these groups are for this reason not used in the SINimilarity tool. Inorganic compounds and many salts are not suited for the similarity methods used in SINimilarity. This is especially true for many compounds in the metal groups. The similarity will be too low to be shown. If the substance contains a group specific metal, it will be identified, which is the most useful information on metals in the majority of all cases.
What is the difference between QSAR and SINimilarity?
QSAR relate mathematical descriptions of chemical structures and measured activities to be able to predict the activities of new chemicals. SINimilarity builds on the methods often used in in QSAR to assess similarity but we are not using measured activities. SINimilarity is a search tool that finds predefined structural elements in molecules and assess similarity between molecules. SINimilarity can not predict toxicity but can easily be used by anyone.
Would ChemSec like the SINimilarity tool to be used in legislation?
No, the SINimilarity tool could not be used in legislation but could hopefully inspire policy makers to find ways to deal with groups of chemicals in the future, instead of restricting one substance at a time which in many cases will lead to a shift to a similar substance, with similar hazardous properties but with a different CAS number.