As part of the REACH regulation ECHA maintains a list of Substances of Very High Concern (SVHC’s). Substances are added to this list if they are deemed to represent a threat to human health or the environment. Examples would include substances that are found to be carcinogenic, mutagenic or toxic, or those that are found to be very bioaccumulative or persistent in the environment. Following inclusion on this list, ECHA may choose to impose restrictions on the use of these substances to try and minimise their potential dangers.

ECHA aims to update its list of SVHC’s quarterly, and did so most recently on 29/06/18, with the addition of the following 10 substances:

1. Benzo[ghi]perylene
2. Decamethylcyclopentasiloxane (D5)
3. Disodium octaborate
4. Dodecamethylcyclohexasiloxane (D6)
5. Ethylenediamine
6. Lead
7. Octamethylcyclotetrasiloxane (D4)
8. Terphenyl hydrogenated
9. Benzene-1,2,4-tricarboxylic acid 1,2-anhydride (trimellitic anhydride)
10. Dicyclohexyl phthalate (DCHP)

Given that cyclopentasiloxane (D5) is present in many cosmetic products the addition of these substances to the SVHC list demonstrates the need for cosmetic manufacturers and brand owners to remain continuously aware of the evolving nature of the REACH regulation.

D5 (Along with D4 and D6) has had the following restriction placed on its use: Cyclopentasiloxane (D5) shall not be placed on the market in wash-off cosmetic products in a concentration equal to or greater than 0,1% by weight of either substance, after 31 January 2020. This restriction has been proposed for some time, but ECHA has now decided to proceed with its implementation despite the objection of some manufacturers and downstream users.

Clearly this will need to be a consideration for cosmetic manufacturers and brand owners in the coming years as some products will require reformulation to ensure compliance before the deadline….ideally the sooner the better!

If you would like assistance in ensuring that you are always fully prepared for any regulatory changes resulting from REACH please contact luke.fenn@msl.io