"Let he who is without SIN . . . . . ."

"Let he who is without SIN . . . . . ."

Last week, Environmental NGOs in the European Union released their long-promised "SIN List" of chemical substances that the activist community in the EU believes should be designated as Substances of Very High Concern (SVHCs) under the REACH regulation.  SIN, which stands for "Substitute it Now," is an unfortunate acronym for this list, which contains 300 chemical substances alleged to present a risk human health and/or the environment.  While it doesn't have any official standing, the SIN list is intended to prod European regulators to use their authority under REACH more aggressively to ban numerous chemicals from the market except for narrowly prescribed uses.  So far, EU member states have nominated 16 chemicals for the SVHC list and the European Commission is accepting stakeholder comment on whether the nominations are justified or should be withdrawn.  This isn't nearly fast enough for the NGOs, who for better or worse foresee monumental change in the way all chemicals are marketed, managed, and used in the EU over the next decade. 

Electrical product manufacturers mostly feel the impact of REACH as producers of articles, which are manufactured goods or products that contain chemicals.  Special rules apply and key questions include whether the "article" contains a chemical substance that is intended to be released during normal and reasonably foreseeable conditions of use, or if the article, regardless of whether a release occurs, contains an SVHC.  

With REACH in place and other countries (including the US) focusing intently on chemicals in commerce, manufacturers can no longer avoid a diligent effort to identify chemical substances present in electrical products and their components.  The sooner a systematic materials declaration/identification mechanism is in place the better, as the list of chemicals under scrutiny by regulators is growing rapidly.  


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