The European REACH regulation addressing the production and use of chemical substances requires (article 33) manufacturers or retailers to inform consumers when a product contains more than 0.1% of substances known as SVHCs—“Substances of Very High Concern”. Upon the consumer’s request and within 45 days, they are required to provide at least the name of the substances and any potential precautions for use.
This “right to know” provides consumers with the opportunity to choose the products they use on a daily basis based on knowledge of the chemicals that the products contain (or don’t contain). The consumer therefore has the ability to exert direct influence on the development of manufacturers’ substitution strategies, which can in turn lead to the use of the most hazardous chemical substances being abandoned altogether.
Businesses’ widely unknown “obligation to inform”
A European Chemicals Agency (ECHA) survey published in November 2019 showed that 88% of suppliers of products that contain more than 0.1% of an SVHC do not communicate sufficient information to their customers about the SVHCs present in the products they supply.
Analyses carried out as part of the European LIFEAskREACH project on everyday consumer goods, such as artificial Christmas trees, baubles, and string lights in three European countries (Austria, Germany, and the Czech Republic) demonstrated these results.
33 samples (15 artificial Christmas trees, 11 baubles, and 7 sets of string lights) were looked at for SVHCs, such as plasticisers, flame retardants, lead, and chlorinated paraffins. 50% of the samples contained SVHCs in quantities greater than 0.1%, therefore requiring that consumers be informed. The SVHCs that were discovered were all endocrine disruptors, some were classified as “POPs” (“persistent organic pollutant”), and one of the substances was classified as toxic to reproduction.
The LIFEAskREACH project filed a request for information: none of the retailers replied within the 45-day regulatory deadline, and some appeared to ignore their obligation to state the presence of SVHCs.
The aims of the LIFEAskREACH project
The LIFEAskREACH project, in which Ineris participates as a national assistance service for the REACH regulation, is intended for both consumers and businesses. It seeks to raise awareness among consumers of their “right to know”, and among businesses of their “obligation to inform”, throughout the supply chain.
The project also seeks to test a smartphone application that is linked to an article database, which would improve communication between consumers and businesses, as well as between producers, suppliers, and retailers. The application will be available at the beginning of 2020.
Substances of Very High Concern (SVHCs)
According to the definition found within article 57 of the REACH regulation, Substances of Very High Concern are defined as:
- substances classified as carcinogenic, mutagenic, and toxic for reproduction (CMR) from categories 1A and 1B
- substances classified as persistent, bioaccumulative, and toxic (PBT), and classified as very persistent and very bioaccumulative (vPvB)
- substances presenting an “equivalent level of concern” to CMR, PBT, and vPvB substances (endocrine disruptors fall into this category).
