Identification of Substances of Very High Concern
► What are the characteristics of relevant SVHCs? Preparing the Annex XV report and Public Consultation
1. In Practice
During the public consultation for the identification of an SVHC, ECHA calls for comments related to the substance identity (i.e. on the substance name/EC number/CAS number/molecular structure etc.) and/or intrinsic properties used to justify the identification.
SVHC proposals based on harmonised classifications and labelling (CLH) included in the CLP Regulation cannot be challenged in the SVHC identification process. Comments questioning CLH will not be considered in this context. Other comments, particularly those on uses, exposures, alternatives etc., can be made and will be taken into account at the next stage in the process.
Although not directly relevant for the identification of the SVHC, these comments are important for the discussion to recommend whether the substance be included in the Authorisation List.
It is recommended to coordinate the preparation of the comments throughout the supply chain and to have only one set of comments submitted by a trade association or a cross sector group. However, companies are invited to submit separately specific or confidential information which could support the future prioritization work.
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