Dear valued customers,

This is to inform you that European Chemical Agency (ECHA) updated its list of proposed Substances of Very High Concern (SVHCs) prescribed in Article 59 of Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) on September 3, 2021 and that this includes a chemical substance that is used as an ingredient in some of the products Polyplstics offers. This chemical substance, whose chemical name and CAS No. are as shown below, has been proposed as an SVHC by Denmark.
https://echa.europa.eu/substances-of-very-high-concern-identification

Substance
6,6′-di-tert-butyl-2,2′-methylenedi-p-cresol (CAS No.119-47-1)

For the exact concentration of the substance (CAS No.119-47-1) in these products and other related questions, please make inquiries using our official inquiry site.

At this point, however, whether or not this substance (CAS No.119-47-1) will indeed be designated as an SVHC is yet to be discussed in ECHA. ECHA usually updates its list of SVHCs twice a year; January and July. Polyplastics recommends that its customers pay close attention to the information announced by ECHA in and around these months.

Notification requirements in case the substance is designated as an SVHC

In case the substance (CAS No.119-47-1) is designated as an SVHC, importers and manufacturers of articles in EU containing the substance  (CAS No.119-47-1) above the threshold concentration (0.1 wt%) will be required to submit the following notifications according to the procedure prescribed by ECHA. For more information, refer to the following URL.

1.Notification to SCIP database

Who needs to submit a notification:
Importers and manufactures of articles containing the substance (CAS No.119-47-1) above 0.1 wt% in EU regardless of the amount of import/manufacture.

Notification deadline:
Day of the first import/manufacture of articles after the substance is designated as an SVHC.

https://echa.europa.eu/scip

2.Notification to ECHA

Who needs to submit a notification:
Importers and manufactures of articles containing the substance (CAS No.119-47-1) above 0.1 wt% in EU, for whom the total amount of the substance exceeds 1 metric ton/year.

Notification deadline:
Within 6 months from the date the substance is designated as an SVHC.

https://echa.europa.eu/support/dossier-submission-tools/reach-it/notifying-substances-in-articles

Polyplastics is planning on proposing its customers to switch to alternative products (formulation changes or existing products with similar properties). Polyplastics, however, would like its customers to recognize that there is a possibility that the substance will be designated as an SVHC before switching to such alternative products has been completed. In that case, customers will need to comply with the notification requirements mentioned above.

If you have any questions, please use the following inquiry website or contact our sales representatives.

Polyplastics Inquiry Website
Please make inquires using the subject heading “SVHC” from the link below.
Polyplastics official website inquiry  

Sincerely yours,

Yoichi Kurokawa
Chief
Quality Assurance Department

※: DURACON® is a registered trademark of Polyplastics Co., Ltd. in Japan and other countries.

Disclaimer:

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