The European Chemicals Agency (ECHA) has launched public consultations on the potential identification of three substances as Substances of Very High Concern (SVHCs) under REACH Regulation (EC) No 1907/2006. The substances under review are:
- Decamethyltetrasiloxane (EC 205-491-7, CAS 141-62-8) – proposed by Norway due to its very persistent and very bioaccumulative (vPvB) properties.
- 1,1,1,3,5,5,5-Heptamethyl-3-[(trimethylsilyl)oxy]trisiloxane (EC 241-867-7, CAS 17928-28-8) – proposed by Norway for the same vPvB concerns.
- Reactive Brown 51 (EC 466-490-7) – proposed by Sweden, classified as toxic for reproduction (Repr. 1B).
Stakeholders have until 14 April 2025 to submit their comments on these proposals, particularly regarding uses, alternatives, exposure risks, and potential regulatory impact. If identified as SVHCs, these substances will be added to the Candidate List for Authorisation, leading to further restrictions.
Industry Impact and Regulatory Considerations
Decamethyltetrasiloxane & Heptamethyltrisiloxane
Both decamethyltetrasiloxane and heptamethyltrisiloxane are widely used in cosmetics, personal care products, and industrial applications. These substances serve as silicone-based ingredients in skincare and haircare and as processing aids in industrial formulations.
Inclusion in the Candidate List could impose supply chain disruptions, substitution costs, and disclosure requirements for businesses. Manufacturers may need to assess alternative ingredients and compliance strategies ahead of potential regulatory action.
Reactive Brown 51
Reactive Brown 51 is used in textile treatment and dyeing applications. The Swedish authorities have proposed its SVHC classification due to its toxic effects on reproduction (Repr. 1B).
If listed as an SVHC, businesses may need to provide detailed reporting on its use and consider alternative dyeing technologies. The textile and leather industries, in particular, should prepare for potential restrictions affecting product formulations and manufacturing processes.
Next Steps for Stakeholders
ECHA encourages all affected parties, including manufacturers, downstream users, NGOs, and researchers, to submit comments by 14 April 2025. The feedback will be reviewed by the Member State Committee (MSC) before a final decision is made on SVHC identification.
Businesses should evaluate their regulatory obligations, consider alternatives, and engage in the consultation process to ensure their interests are represented.
