SVHC listed substances：UV-320, UV-327, UV-328, UV-350
SVHC, a substance of high concern, is derived from the European REACH regulation. According to Article 57 of REACH Regulation, SVHC is determined according to the following standards. Substances with very high degree of concern and serious consequences. Substances that meet the conditions can be placed in a list.
At present, several UV absorbers are listed in the SVHC List, including UV-320/327/328/350.
COMMENTS ON AN ANNEX XV DOSSIER FOR IDENTIFICATION OF A SUBSTANCE AS SVHC AND RESPONSES To THESE COMMENTS
Substance name: 2-benzotriazol-2-yl-4,6-di-tert-butylphenol (UV-320)
CAS number: 3846-71-7
EC number: 223-346-6
The substance is proposed to be identified as meeting the following SVHC criteria set out in Article 57 of the REACH Regulation: PBT (Article 57 (d)); vPvB (Article 57 (e))
Disclaimer: Comments provided during public consultation are made available as submitted by the commenting parties. It was in the commenting parties own responsibility to ensure that their comments do not contain confidential information. The Response to Comments table has been prepared by the competent authority of the Member State preparing the proposal for identification of a Substance of Very High Concern. RCOM has not been agreed by the Member State Committee nor has the document been modified as result of the MSC discussions.
PART I: Comments and responses to comments on the SVHC proposal and its justification
General comments on the SVHC proposal
|
No. |
Date |
Submitted by(name,Organisation/ MSCA) |
Comment |
Response |
|
5 |
2014/10/16 |
International NGO Health and Environment Alliance Belgium |
we support the nomination of UV 320 to the Candidate list and thank Germany for submitting it and including data related to its presence in house dust. |
Thank you for your support. |
16 OCTOBER 2015
COMMENTS ON AN ANNEX XV DOSSIER FOR IDENTIFICATION OF A SUBSTANCE AS SVHC AND RESPONSES TO THESE COMMENTS
Substance name: 2,4-di-tert-butyl-6-(5-chlorobenzotriazol-2-yl)phenol (Uv-327)
CAS number: 3864-99-1
EC number: 223-383-8
The substance is proposed to be identified as meeting the following SVHC criteria set out in Article 57 of the REACH Regulation: vPvB (Article 57 e)
Disclaimer: Comments provided during public consultation are made available as submitted by the commenting parties. It was in the commenting parties own responsibility to ensure that their comments do not contain confidential information. The Response to Comments table has been prepared by the competent authority of the Member State preparing the proposal for identification of a substance of very high concern.
PART I: Comments and responses to comments on the SVHC proposal and its justification
General comments on the SVHC proposal
None
Specific comments on the justification
|
Number / Date |
Submitted by (name, submitter type, country) |
Comment |
Response |
|
4496 2015/10/12 |
Sweden, Member State |
The Swedish CA agrees that 2,4-di-tert-butyl-6-(5-chlorobenzotriazol-2- yl)phenol (UV-327) meets the criteria according to Article 57(e) in REACH and is thus eligible for identification as a substance of very high concern.
|
Thank you for your support.
|
16 OCTOBER 2015
COMMENTS ON AN ANNEX XV DOSSIER FOR IDENTIFICATION OF A SUBSTANCE AS SVHC AND RESPONSES TO THESE COMMENTS
Substance name: 2,4-di-tert-butyl-6-(5-chlorobenzotriazol-2-yl)phenol (Uv-327)
CAS number: 3864-99-1
EC number: 223-383-8
The substance is proposed to be identified as meeting the following SVHC criteria set out in Article 57 of the REACH Regulation: vPvB (Article 57 e)
Disclaimer: Comments provided during public consultation are made available as submitted by the commenting parties. It was in the commenting parties own responsibility to ensure that their comments do not contain confidential information. The Response to Comments table has been prepared by the competent authority of the Member State preparing the proposal for identification of a substance of very high concern.
PART I: Comments and responses to comments on the SVHC proposal and its justification
General comments on the SVHC proposal
None
Specific comments on the justification
|
Number / Date |
Submitted by (name, submitter type, country) |
Comment |
Response |
|
4496 2015/10/12 |
Sweden, Member State |
The Swedish CA agrees that 2,4-di-tert-butyl-6-(5-chlorobenzotriazol-2- yl)phenol (UV-327) meets the criteria according to Article 57(e) in REACH and is thus eligible for identification as a substance of very high concern.
|
Thank you for your support.
|
17 November 2014
COMMENTS ON AN ANNEX XV DOSSIER FOR IDENTIFCATION OF A SUBSTANCE AS SVHC ANDRESPONSES To THESE COMMENTS
Substance name: 2-(2H-benzotriazol-2-yl)-4,6-ditertpentylphenol (Uv-328)
CAS number: 25973-55-1
EC number: 247-384-8
The substance is proposed to be identified as meeting the following SVHC criteria set out in Article 57 of the REACH Regulation: PBT (Article 57(d)); vPvB(Article 57 (e))
Disclaimer: Comments provided during public consultation are made available as submitted by the commenting parties. It was in the commenting parties own responsibility to ensure that their comments do not contain confidential information. The Response to Comments table has been prepared by the competent authority of the Member State preparing the proposal for identification of a Substance of Very High Concern. RCOM has not been agreed by the Member State Committee nor has the document been modified as result of the MSC discussions.
PART I: Comments and responses to comments on the SVHC proposal and its justification
General comments on the SVHC proposal
|
No. |
Date |
Submitted by(name,Organisation/ MSCA) |
Comment |
Response |
| 2 | 2014/10/15 | Company Belgium
|
Full comments are provided in the attachments.
Authorisation is not the appropriate route as certain risks suggested in the Anne XV cannot be controlled by the authorisation process.
|
Thank you for your comments.
With regard to the best RMO-strategy the RMO-assessment conducted by Germany came to a different conclusion than yours. Due to limited information we cannot conclude there is an existing risk according to article 69(4) of REACH. Furthermore, we also lack the detailed knowledge for assessing the availability of feasible alternatives,especially considering the specialised uses of these substances. As you yourself describe there are currently no feasible alternatives available. We therefore concluded that the phenolic benzotriazoles exhibiting SVHC- properties should be regulated via authorisation and be substituted in the long run (when feasible alternatives are available). This assessment is supported by relevant uses
|
| 2_2014-10-15 UV-328 consultation Cand List-non-confidential-public.pdf
Confidential attachment removed
|
16 October 2015
COMMENTS ON AN ANNEX XV DOSSIER FOR IDENTIFICATION OF A SUBSTANCE AS SVHC AND RESPONSES TO THESE COMMENTS
Substance name: 2-(2H-benzotriazol-2-yl)-4-(tert-butyl)-6-(sec-butyl)phenol (UV-350)
CAS number: 36437-37-3
EC number: 253-037-1
The substance is proposed to be identified as meeting the following SVHC criteria set out in Article 57 of the REACH Regulation: vPvB (Article 57 e)
Disclaimer: Comments provided during public consultation are made available as submitted by the commenting parties. It was in the commenting parties own responsibility to ensure that their comments do not contain confidential information. The Response to Comments table has been prepared by the competent authority of the Member State preparing the proposal for identification of a substance of very high concern.
PART I: Comments and responses to comments on the SVHC proposal and its justification
General comments on the SVHC proposal
None
Specific comments on the justification
|
Number / Date |
Submitted by (name, submitter type, country) |
Comment |
Response |
| 4497
2015/10/12 |
Sweden,
Member State |
The Swedish CA agrees that
2-(2H-Benzotriazol-2-yl)-4-(tert-butyl)-6-(sec-butyl)phenol (UV-350) meets the criteria according to Article 57(e) in REACH and is thus eligible for identification as a substance of very high concern.
|
Thank you for your support.
|
| 4500
2015/10/12
|
Norway,
Member State
|
The Norwegian CA supports the proposal to identify 2-(2H-benzotriazol-2-yl)-4-(tert-butyl)-6-(sec-butyl)phenol (UV-350) as a substance of very high
concern based on its vPvB properties and should be included in the Candidate List. Concerning monitoring data a screening report from Norway has been published, which includes findings of several UV filters in the environment similar to UV 350(benzotriazoles UV 327,328 and 329). http: //www.miljodirektoratet.no/Documents/publikasjoner/M176/M176.pdf These findings support that UV 350 and similar UV substances may
|
Thank you for the support, the
information from the study is already included in Annex I.E of the support document.
|
Candidate List of substances of very high concern for Authorisation
(published in accordance with Article 59(10) of the REACH Regulation)
Notes:
Candidate List of substances of very high concern for Authorisation
(published in accordance with Article 59(10) of the REACH Regulation)
Notes:
Candidate List of substances of very high concern for Authorisation
(published in accordance with Article 59(10) of the REACH Regulation)
Notes:
Post time: Nov-17-2022