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Take a look at the bigger picture

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The SIN List - a constant reminder of what REACH is all about

Focus - ECHA Member State Committee

Ninja Reineke, WWF

The SIN list plays a very important role in my work for a strong and effective implementation of REACH, and especially in my role as an observer for WWF in the Member State Committee of the European Chemicals Agency (ECHA).


This committee, with representatives from all 27 EU Member States, takes decisions on substances of very high concern (SVHCs) and selects the most urgent ones for authorisation. WWF and Greenpeace follow these official discussions about the REACH ‘candidate list’ (the list of SVHCs) to provide scientific input and participate in the exchange of arguments on identifying and prioritizing SVHC. As there may be a few thousand SVHCs on the European market, the SIN list of 267 chemicals helps us focus our work on a ‘manageable’ number of priority chemicals. Moreover, it demonstrates the obvious lack of speed and action of the official process, given that so far only 15 chemicals have made it on the official ‘candidate list’.



Slow bureaucratic procedures

To speed up the substitution of SVHCs by safer alternatives, we believe all classified CMRs and PBTs and other chemicals of concern such as identified endocrine disruptors should have been transferred immediately on to the first candidate list. However, decisionmakers opted for a highly bureaucratic procedure instead where: a) a member state, or ECHA on behalf of the Commission, prepares technical dossier(s) proposing SVHC(s) and submits it (them) to ECHA; b) the Member State Committee decides whether the chemical fulfils the criteria of being a SVHC.


Since Member States authorities must choose which chemicals to propose and support for the REACH candidate list and thus for authorization or restriction procedures,they have a large interest in the SIN list. From our bilateral exchanges with chemical experts in the national ministries, we know that the SIN list serves as an inspiration and model: on the methodology for selection, on hazard data, or biomonitoring data. And irrespective of whether authorization or restriction is the best route for controlling a particular SVHC, the NGO REACH coalition calls for all SVHCs to first be placed on the candidate list because this legally guarantees the public right to know about their presence in consumer products and the transmission of information amongst all actors in the supply chain.


Extended list of substances needed

Thanks to NGO presence and advocacy efforts, there is now a growing consensus that the ‘candidate list‘ must expand significantly. But how long will that take? The next round of submission of proposals to add to the 15 substances so far on the “Candidate list” is in the beginning of August this year and so far only 12 chemicals have been listed as potential nominees (5 of them being anthracene oils and 5 coal tar compounds, one phthalate and one dinitrotoluene). This number is still far too small.


7 out of 15 prioritized for authorisation

On 1st June 2009, ECHA recommended that 7 of the 15 official candidates should go onto the authorization list. This means their uses must be stopped by a certain date in the future (expect the earliest as late as 2013) unless a company gets an authorization for continued use. In the public consultation, CHEM Trust, Greenpeace, HEAL and WWF supported the prioritization of these 7 chemicals, but argued for shorter timelines, less exemptions, and the consideration of cumulative effects for the 3 phthalates. The final decision to put these 7 chemicals on the authorization list will be taken by the European Commission together with Member States (through a committee process known as comitology) later this year.


Looking at the new science coming out daily which links certain chemicals to serious health effects and the urgency of addressing the problems behind these data, the REACH system is working inappropriately slowly. In many ways it seems that we are back to a chemical-by-chemical approach. Of course this is not only due to bureaucratic procedures. There are also lots of short term, very narrow economic interests at stake, which are often in direct conflict with taking protection measures for health and environment.


We will need more SIN to keep up the pressure and fill the vacuum

In light of this dismayingly slow speed, the SIN list must continue playing its very important role: encouragement and guidance for companies, a guiding mark for policymakers and a warning to the public that we are still far from having safe products. The SIN list acts as a constant reminder that REACH should achieve the replacement of SVHCs, and the SIN list will continue to gain momentum regardless of the pace of the official process.



Ninja Reineke, Senior Policy Officer, Chemicals, at the WWF European Policy Office, observer in the ECHA Member State Committee and member of the SIN List Advisory Committee.