New REACH SVHC Webinar

AS SENTCOM PLIANCE
info@assenTcompliance.com w w w. a s s e n T c o m p l i a n c e . c o m Tel: 613.290.8044

REACH
June 2012’s New SVHCs
Assent Compliance

Krystal Noseworthy-Baker
phone: 613.882.1429
krystal.baker@assentcompliance.com

C u s t o m s o l u t i o n s f o r c o m p l i a n c e [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]

AS SENTCOM PLIANCE

Introduction to Assent Compliance

Assent Compliance
• Consulting
• Global Requirements
• Compliance Strategies
• Regulatory Interpretations and Impacts
• IT
• Cloud Computing
• Application Design
• Operations
• Program Implementation
• Data Management

C u s t o m s o l u t i o n s f o r c o m p l i a n c y [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]

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Agenda


• Latest Additions to the SVHC Candidate List
• Industries affected by the June 2012 SVHCs
• Requirements for SVHCs
• Communication
• Notification
• Authorization
• Registry of Intentions – SVHC Candidate List
• What is coming and where are they used?
• Consulting Services
• Software Services
• Q&A

C u s t o m s o l u t i o n s f o r c o m p l i a n c y [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]

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 SVHC Candidate List
JUNE 18th 2012 Addition
• 13 Added, 4 Consolidated to 2, Total is 84 SVHCs

EC CAS
Substance Uses/materials
Number Number
• Inert solvent for grignard-, reduction- and alkylation-reactions.
• Part of absorbing liquids in the industrial cleaning of gases
(gas scrubber)
1,2-bis(2-methoxyethoxy)ethane
203-977-3 112-49-2 • Possibly be used as a catalyst for certain phase –transfer reactions
(TEGDME; triglyme)
• Also reported to be used in the formulation of electrolyte systems
for lithium batteries
• Reported to be used in Brake fluids.

C u s t o m s o l u t i o n s f o r c o m p l i a n c E [ REAC H | R o H S | CP s i a | RSL | p r o p 6 5 ]

AS SENTCOM PLIANCE

• The use of EGDME as substance or in mixture is restricted to
industrial and professional users.
• EGDME is mainly used as an inert special solvent for grignard-,
reduction- and alkylation-reactions.
• Also useful as an inert solvent for organo metallic reactions in
general, e.g reactions involving alkali metals such as lithium, so-
dium and potassium, Pd catalyzed couplings (Suzuki reaction)
• Also used as solvent a for electrolytes of lithium batteries and as
a process solvent for the recycling of Li-batteries
• Used in a process for the surface treatment of aluminium in
1,2-dimethoxyethane; ethylene order to ensure surfaces are less reactive
203-794-9 110-71-4
glycol dimethyl ether (EGDME) • Likewise as an industrial reaction solvent, it facilitates cer-
tain reactions including use as a solvent to facilitate forma-
tion of alkali metal-hydrocarbon adducts and it is used in the
Reformatsky reaction with methyl gamma-bromocrotonate
• Also used as cleaning solvent and within solder fluxes within
the microelectronics industry.
• One confirmed use in a consumer product, as an electrolyte
solvent (1-5%) in sealed lithium ion batteries.
• Also used as a constituent within flexo gravure water-solvent
based inks, lithographic plate developers and glass cleaning
solvents


AS SENTCOM PLIANCE

• EU Uses: Formulation and production of writing inks.
• Solvent Violet 8 is used in inks and dyes
• Dyeing a variety of materials, list includes: paper (copying,
carbon), packaging, distemper, wood, lacquers, plastics, and
feathers; while chemical catalogues refer additionally to uses
in leather, as well as in candle and rubber; there are also ref-
erences to use in black dyes for polyacrylonitrile materials.
Furthermore, according to the Colour Index potential uses
include also dyeing of oil and fat products, as well as soaps.

4,4’-bis(dimethylamino)-4’’- • The products (dyestuff) containing Solvent Violet 8 could
209-218-2 561-41-1 have a diluent, but it would have to be soluble in solvents that
(methylamino)trityl alcohol*
are used to dissolve the dye. The commercial products listed
can be supplied as powders or as pastes used for ballpoint pens,
coatings on carbon paper, spirit inks, etc. (personal communi-
cation with Society of Dyers and Colourists).
• At the website of an Indian company Solvent Violet 8 is re-
ported to being extensively used in fertilizers.
• Finally, the literature refers to uses of Solvent Violet 8 in di-
agnostic, analytical, and R&D applications, such as biological
stain, while in chemical catalogues it is also reported to be used
as anti-allergen and bactericide.

*
Note:
Uses in literature: Although some companies that submitted classification and labelling notifications indicated “Solvent Violet 8” as a synonym of the
substance 4,4’-bis(dimethylamino)-4’’- (methylamino)trityl alcohol), the Colour Index International identifies Solvent Violet 8 with EC and CAS numbers
which do not match the numerical identifiers of the substance 4,4’- bis(dimethylamino)-4’’-(methylamino)trityl alcohol). The information on potential
uses/applications refers to Solvent Violet 8 and the products containing, as it is cited by public on-line sources.


AS SENTCOM PLIANCE

• Michler’s ketone is an important intermediate in the manufacture
of triphenylmethane dyes.
• The following is an indicative list of substances that are reported to
be manufactured from Michler’s ketone:
• C.I. Acid Blue 34; C.I. Acid Blue 86;C.I. Acid Blue 88; C.I.
Acid Violet 15; C.I. Acid Violet 38; Acid Violet 2B; C.I. Basic
Orange 23; C.I. Basic Violet 3; C.I. Basic Yellow 2; Ceres Blue
I; Fanal Blue 3B supra; C.I. Solvent Violet 9; C.I. Solvent Yellow
34; Basazol Violet, Basic Brown C2, C.I. Basic Purple 48; Methyl
Violet DAW; C.I. Basic Blue 26 (Gessner and Mayer, 2000).
• References exist also on the use as an intermediate in the manufac-
ture of pharmaceuticals as well as on applications in the produc-
tion of polymers Michler’s ketone is also used as additive in dyes
and pigments, acting as photosensitizer
4,4'-bis(dimethylamino)
202-027-5 90-94-8 • Used in photoinitiation systems
benzophenone (Michler’s ketone)
• Used as curing agent in ultraviolet (UV)-cured printing inks for
cartonboard, acting as a catalyst to harden ink when it is exposed
to UV light during the printing process
• In the literature there are further reports on the use of Michler’s
ketone as light absorbent, as well as in photoresist formulations
• Also mentioned to be used as a component in dry film products
and as a process chemical for electronic circuit board manufacture
• Some analytical applications are listed as well
• Used in repackaging and in Research & Development.
• Colouring agent in the manufacture / production of paper and
paper products. As mentioned above, it cannot be excluded that
Michler’s ketone is rather present as impurity in other substance(s)
used as colouring agents.


AS SENTCOM PLIANCE

The main uses are:
• Dye in ink applied in cartridges for printers and in ball pens and
as dyestuff for paper colouring.
[4-[4,4'-bis(dimethylamino) • Minor dyestuff uses include carbon papers (where dyestuff is sus-
benzhydrylidene]cyclohexa-2, pended in wax and applied to a thin impregnated paper), staining
208-953-6 548-62-9 of dried flowers/plants (dried plants dyed by immersion in a hot
5-dien-1-ylidene]dimethylammo- water solution of the dyestuff) and as a marker (i.e. where dyestuff
nium chloride (C.I. Basic Violet 3) is used to improve the visibility of a liquid).
• Also used in microbial and clinical laboratories (e.g. as stain to dis-
tinguish gram negative from gram positive bacteria) in presumably
thousands of laboratories and teaching institutions around Europe.
• Basic Blue 26 is used in inks, dyes, paints, and pigments.
• Furthermore, Basic Blue 26 or its products are used for dyeing a
variety of materials, such as paper, distemper, wood, and fibres/
textiles.
• The commercial product (dyestuff) containing C.I. Basic Blue 26
may be a pure powder, a powder with diluents, or a solution with
or without diluents.
[4-[[4-anilino-1-naphthyl] • Uses relating to cosmetic products including hair products, cray-
[4-(dimethylamino)phenyl]methy- ons, and soaps.
lene]cyclohexa-2,5-dien-1-ylidene] 219-943-6 2580-56-5 • Finally, the literature refers to uses of Basic Blue 26 in diagnostic,
analytical, and R&D applications, such as biological stain.
dimethylammonium chloride (C.I.
Basic Blue 26) • Production of various inks
• Cleaners
• Coating applications
• Dyeing of various paper and plastic products (e.g. paper towel
wipes , low grade paper and paper food trays, and other products)
• Dyeing or painting of other articles
• Ink in printing industry


AS SENTCOM PLIANCE

• Glass Production (Borosilicate and crystal glass)
• Glass fibre production
• Frits production
• Refractories
• Use of Borates in Metallurgy
• Flame Retardants
• Nuclear applications
• catalysts
• Use of Borates polymer production
• Intermediate use in the production of non-oxide ceramic powders
Diboron trioxide 215-125-8 1303-86-2
• Use of Borates in detergents and cleaners
• Use of Borates in Industrial Fluids
• INKS/PAINTS
• Production of monocrystalline gallium arsenide wafers
• Reagent chemicals
• Agriculture
• Construction materials
• Adhesives
• Crystal growth
• Use of substance for production


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• Not registered for consumer use.
• BUT measured in wooden toys and foam puzzle mats as well as in
fitness and exercise mats which are made of ethylene vinyl acetate
(EVA).
• Not possible to characterise the origin for its presence in foam
puzzle mats - Assumed that formamide is associated with a blow-
ing agent used in the creation of foam and other consumer prod-
Formamide 200-842-0 75-12-7
ucts, particularly those produced from EVA foam, that contain
formamide, too.
• Foam toys were also found to contain formamide.
• Formamide is used as a solvent and plasticizer in consumer prod-
ucts. It can be an ingredient as softener for paper, animal glues
(which is mainly used for gluing wood), water soluble glues and
wood stains

• Solutions of lead(II) bis(methanesulfonate) are used in plating
Lead(II) bis(methanesulfonate) 401-750-5 17570-76-2 (both electrolytic and electroless).
• These products are used in tin-lead plating.


AS SENTCOM PLIANCE

• Used as a chemical intermediate in the manufacture of dyes and
pigments, including Methylene red, C.I. Basic Yellow 2, Basic
Orange 14, Solvent Orange 15, and Solvent Yellow 34
• Also used as chemical intermediate in the manufacture of its hy-
N,N,N',N'-tetramethyl-4,4'- drochloric salt. The latter is used as an analytical reagent for the
202-959-2 101-61-1 determination of lead.
methylenedianiline (Michler’s base)
• Chemical reagent in Research & Development.
• Use as a colouring agent in production of paper and paper products.
• As mentioned above, it cannot be excluded that Michler’s base is pres-
ent as impurity in substance(s) included in the imported mixtures.
• TGIC is an epoxy compound that is used as a hardener in resins
and coatings.
• Main use is in polyester powder coatings for metal finishing and
such coatings typically contain between 4 and 10% TGIC.
• In Europe - used in weather-resistant powder coatings since the
1970s for coating articles such as steel garden furniture, car parts,
metal fencing, window and door frames.
TGIC (1,3,5-tris(oxiranylmethyl)-
• Also used for powder coating electrical equipment, refrigerators,
1,3,5-triazine-2,4,6(1H,3H,5H)- 219-514-3 2451-62-9 washing machines and ovens.
trione) • May also be used in inks in the printed circuit board industry, for
example two-part inks used for solder-masking can contain up to
around 60% TGIC in the hardener component.
• Other uses reported include in electrical insulation materials, resin
moulding systems, laminated sheeting, silk-screen printing coat-
ings, tools, adhesives, lining materials and stabilisers for plastics.
The technical grade substance is supplied under the trades names
TEPIC, Araldite PT 810 or TK 10622.


AS SENTCOM PLIANCE

• Used in inks and dyes.
• Solvent Blue 4 or its products are used for dyeing a variety of mate-
rials, such as paper (e.g. carbon paper), distemper, wood, lacquers,
feathers, and plastic.
• May also be used in fuel .

α,α-Bis[4-(dimethylamino)phenyl]-4 • Also reported to being extensively used in fertilizers.
(phenylamino)naphthalene-1-meth- 229-851-8 6786-83-0 • Uses relating to cosmetic products are also listed (eg.soaps)
anol (C.I. Solvent Blue 4) • Finally, the literature refers to uses in diagnostic, analytical, and
R&D applications, such as biological stain.
• Production of various inks, e.g. for printing (inks in publication
gravure printers) or writing
• Dyeing of paper
• Use in mixtures such as windscreen washing agents


AS SENTCOM PLIANCE

• TGIC is an epoxy compound that is used as a hardener in resins
and coatings.
• Main use is in polyester powder coatings for metal finishing
• Such coatings typically contain between 4 and 10% TGIC.
• In Europe - used in weather-resistant powder coatings since the
1970s for coating articles such as steel garden furniture, car parts,
metal fencing, window and door frames.
β-TGIC (1,3,5-tris[(2S and 2R)-2,3-
• Also used for powder coating electrical equipment, refrigerators,
epoxypropyl]-1,3,5-triazine-2,4,6- 423-400-0 59653-74-6
washing machines and ovens.
(1H,3H,5H)-trione)
• May also be used in inks in the printed circuit board industry, for
example two-part inks used for solder-masking can contain up to
around 60% TGIC in the hardener component.
• Other uses reported include in electrical insulation materials, resin
moulding systems, laminated sheeting, silk-screen printing coat-
ings, tools, adhesives, lining materials and stabilisers for plastics.
The technical grade substance is supplied under the trades names
TEPIC, Araldite PT 810 or TK 10622.


AS SENTCOM PLIANCE

 Industries Affected
Most Common Uses for the June 2012 SVHCs
TEGDME (triglyme)
EGDME
• Battery Industry
• Automotive Industry (Brake fluids)
• Cleaning Industry (cleaning solvents)
• Microelectronics Industry (solders)
• Printing Industry


AS SENTCOM PLIANCE

 Industries Affected (Continued)
Diboron Trioxide
• Glass industry
• Production (Borosilicate and crystal glass)
• Glass fibre production
• Frits production
• Refractories
• Metallurgy
• Flame retardants
• Nuclear applications
• Polymer Industry
• Detergent and Cleaners Industry
• Inks and Paints Industries
• Semi-Conductor Industry (Production of monocrystalline gallium arsenide wafers)
• Reagents and Catalysts
• Agriculture
• Construction materials
• Adhesives – Multi-Industry Impact


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FORMAMIDE
• Toy and consumer industry (wooden toys, foam toys, foam puzzle mats, solvent and plasticizer
in consumer products)
• Glue manufacturers
• Wood article manufacturers (animal glues and wood stains)

Lead(II) bis(methanesulfonate)
• Electronics Industry (tin-lead plating)

TGIC
β-TGIC
Both epoxy compounds used as a hardener in resins and coatings
• Automotive industry • Silk Screen Printing
• Fencing, Window and Door Manufacturers • Adhesives Industry
• Electronics Industry • Printed Circuit Board (PCB) industry (inks)
• Appliances Industry • Plastics Industry (stabilizer)


AS SENTCOM PLIANCE

CI Basic Violet 3 / CI Basic Blue 26 / CI Solvent Blue 4
4,4’-bis(dimethylamino)-4’’-(methylamino)trityl alcohol
• Inks, Dyes, Paints, Pigments Industry
• paper and paper products
• packaging
• wood
• fibres and textiles
• Analytical reagent and R&D applications
• possible cosmetic use
• cleaners, coating application dyes in wood, lacquers, plastics, leathers
• fuel
• fertilizers


AS SENTCOM PLIANCE

Industries Affected (Continued)
Michler’s ketone / Michler’s base
• Dyes and Pigments Industry
• colouring agent in paper and paper products
• Pharmaceuticals
• Polymer production
• Analytical reagent and R&D applications


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 Requirements
What do new SVHCs mean for your company?
Companies will need to assess whether they have legal obligations resulting from the inclusion of
the new substances in the Candidate List.
The legal obligations related to SVHCs include Communication and Notification.

Communication
Any producers or importers of articles placed on the market1 in the EU must declare the presence
of any of these substances in an article in a concentration exceeding 0.1% w/w.


AS SENTCOM PLIANCE

Article 33 – Source of compliance requirement:
Duty to communicate information on substances in articles:
1. Any supplier of an article containing a substance meeting the criteria in Article 57 and identi-
fied in accordance with Article 59(1) in a concentration above 0,1 % weight by weight (w/w)
shall provide the recipient of the article with sufficient information, available to the supplier,
to allow safe use of the article including, as a minimum, the name of that substance.
2. On request by a consumer any supplier of an article containing a substance meeting the cri-
teria in Article 57 and identified in accordance with Article 59(1) in a concentration above
0,1 % weight by weight (w/w) shall provide the consumer with sufficient information, avail-
able to the supplier, to allow safe use of the article including, as a minimum, the name of that
substance.
The relevant information shall be provided, free of charge, within 45 days of receipt of the request.

1
Article 3.12 of the REACH Regulation specifies:
• Placing on the market: means supplying or making available, whether in return for payment or free of charge, to a third party. Import shall
be deemed to be placing on the market;


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 Requirements
• What does this mean?
• Once a substance has been added to the SVHC List, you must declare its presence to your
downstream users if the concentration is above 0.1% of your products weight.
• This is to be done upon immediately for professional customers and within 45 days from request
for consumers.


AS SENTCOM PLIANCE

 Requirements (Continued)
Notification
Furthermore, these same producers and importers have six months from the date the new SVHCs
were included (18 June 2012) to notify the ECHA if
(a) The (SVHC) is present in those articles in quantities totalling over 1 tonne per producer or
importer per year
(and)
(b) The (SVHC) is present in those articles above a concentration of 0,1 % weight by weight (w/w)

• A notification is created using the same software as a REACH registration – IUCLID.
• It is a much less intense dossier than a registration dossier.
• To facilitate the task of notification, ECHA has made available pre-filled substance datasets
in IUCLID 5.3 format.
• Each Candidate List substance has its own pre-filled dataset, which can be downloaded
from the Candidate List webpage.
• These datasets contain:
»» The identity (substance name, EC and/or CAS number)
»» The classification and labelling of the substance.


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• The following information must be entered by the notifier:
»» identity and contact details,
»» registration number (if available),
»» the tonnage range of the substance,
»» a brief description of the uses of the substance in the article itself and the uses of
the article.
• REACH-IT is the submission tool that must be used.


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Authorisation
Any chemicals placed on the Candidate List can also eventually be approved for an authorization
list where they will then be banned from use unless an authorization is submitted and approved
before the applicable sunset date.
• Most, if not all, substances on the current SVHC List will eventually move onto the Authorisation
list and therefore require an Authorisation for their use.

• Authorisations are required on a per substance, per use, per supply chain (you or an actor up your
supply chain must have been granted an authorisation) basis.


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Review of the Authorisation Process – Annex 15 Dossiers:
1. Registry of intentions – Intention to submit dossier
• 22 Registered, 13 expected to be submitted in August 2012, 4 expected to be submitted in
January 2013, 5 with no expected date of submission

2. Submission of Annex XV dossier (SVHC Dossier) to ECHA for Compliance Check
3. Publication of Annex XV dossier (once it has passed compliance check)
4. After Commenting periods – Candidate List (Article 33 Requirements kick in)
• 13 Added

5. Prioritisation list – Order in which substances will be reviewed for Authorisation
6. Authorisation List – Restrictions and Authorisations handed out


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An Authorisation will contain the following information:
• Substance identity
• Substance intrinsic properties of very high concern,
• Sunset date, date by when a substance can no more be used without authorisation
• Application date, date before which an application for authorisation for each use that is not
exempted from the authorisation requirement must be made, in order to continue to use the
substance for the specific use.
• Review period for uses, if appropriate
• Exempted uses or categories of uses


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 Requirements
Authorization List
Expected
Substance name EC no. CAS no. date of Uses/industries
submission
• hardener for epoxy resins (possible use in PCBs), hardener
4,4'- Diaminodiphenylmethane (MDA) 202-974-4 101-77-9 28.10.2008 in adhesives, intermediate in the manufacture of high-per-
formance polymers, preparation of polyurethane
• plasticizer (softener) in PVC, printing inks, paper and
Dibutyl phthalate (DBP) 201-557-4 84-74-2 28.10.2008
packaging coatings, etc…
• plasticizer (softener) of PVC, acrylics, sealants, adhesives,
Benzyl butyl phthalate (BBP) 201-622-7 85-68-7 28.10.2008
inks, paints, etc..
• plasticiser in polymer products, mainly PVC, blister
Bis (2-ethyl(hexyl)phthalate) (DEHP) 204-211-0 117-81-7 28.10.2008
packing
• dying industry, printing, colored glass, insecticide, metal-
Diarsenic pentaoxide 215-116-9 1303-28-2 28.10.2008
lurgy (to harden copper, lead or gold in alloys), etc…
• decolorizing agent for glass and enamels, oxidizing agent
Diarsenic trioxide 215-481-4 1327-53-3 28.10.2008
special glass and lead crystal formulations, weed killers
5-tert-butyl-2,4,6-trinitro-m-xylene (musk
201-329-4 81-15-2 28.10.2008 • fragrance, cosmetics and soap perfumes
xylene)

3194-55-6,
Hexabromocyclododecane (HBCDD)and
all major diastereoisomers identified: 247- 25637-99-4,

148-4, 134237-50-6, 28.10.2008 • Flame retardant used in HIPS, PS insulation and textiles
Alpha-hexabromocyclododecane
Beta-hexabromocyclododecane 221-695-9 134237-51-7,
Gamma-hexabromocyclododecane
134237-52-8


AS SENTCOM PLIANCE

 • production of toluene diisocyanate - used for the manu-
facture of flexible polyurethane foams. Other: gelatinizing-
2,4-Dinitrotoluene (2,4-DNT) 204-450-0 121-14-2 13.01.2010
plasticizing agent for the manufacture of explosive mixtures
(e.g. forairbags in cars).
• plasticiser for nitrocellulose, cellulose ether, polyacrylate,
Diisobutyl phthalate (DIBP) 201-553-2 84-69-5 13.01.2010 polyacetate dispersions, gelling aid in plastics, lacquers, ad-
hesives, explosive material and nail polish.
• manufacturing pigments and dyes, pigment or coating
agent (industrial and maritime paint products), embalm-
Lead chromate 231-846-0 7758-97-6 13.01.2010 ing/restoring of art products. Other uses: detergents and
bleaches, photosensitive materials and for the manufacture
of pyrotechnic powder.
• colouring, painting and coating agent in sectors such as the
Lead chromate molybdate sulphate red rubber, plastic and paints, coatings and varnishes indus-
235-759-9 12656-85-8 13.01.2010
(C.I. Pigment Red104) tries. Other Applications - agricultural equipment, vehicles
and aircraft as well as road and airstrip painting.
• colouring, painting and coating agent in sectors such as the
rubber, plastic and paints, coatings and varnishes indus-
Lead sulfochromate yellow (C.I.Pigment
215-693-7 1344-37-2 13.01.2010 tries. Other Applications - agricultural equipment, vehicles
Yellow 34)
and aircraft as well as road and airstrip painting, camou-
flage and ammunition marking in the defense area.
• additive plasticiser and viscosity regulator with flame-
retarding properties for acrylic resins, polyurethane, poly-
Tris(2-chloroethyl)phosphate (TCEP) 204-118-5 115-96-8 13.01.2010 vinyl chloride and other polymers. Other applications
- adhesives, coatings, flame resistant paints and varnishes.
Main industries - furniture, textile,building.


AS SENTCOM PLIANCE

 Requirements
SVHC Declaration examples
AMERICAN ZETTLER, INC.
75 COLUMBIA • ALISO VIEJO, CA 92656 • 949-831-5000 • FAX 949-831-8642

To: Supplier Reach Team

From: Ed Edsinga

Date: 10/27/2008 Release date
2/12/2010 Revised Not updated to the most recent SVHC list but the format
6/29/2010 Revised
2/14/2011 Revised
6/25/2011 Revised and necessary elements are otherwise present

Subject: Reach Directive

Supplier Communication of SVHC _ EU Regulation EC 1907/2006_AMERICAN ZETTLER
INCORPORATED

Reach Directive declaration: Valid for all American Zettler Inc. companies:
American Zettler, Zettler Magnetics, Zettler Controls, and AZ Displays.

American Zettler products supplied to customers do not contain any of the reported
substances listed in the SVHC_EU Regulation EC 1907/2006 “list of substances” from
October 28, 2008, added substances f rom January 13, 2010, June 18, 2010 &
December 15, 2010. (Candidate List of Substances of very High Concern – total 53
substances).

Zettler procures articles (not chemicals) which are not intended to release any
substance under normal and reasonable foreseeable conditions of use.

Signed:

Ed Edsinga
Engineering Manager

www.azettler.com


AS SENTCOM PLIANCE

Subject: European Union Regulation (EC) 1907/2006. Updated December 19, 2011. Registration,
Evaluation, Authorization and Restriction of Chemicals. (REACH)

The subject directive undertakes the identification and definition of chemicals of concern, and
preparation of said chemicals, that are contained in products for use in the European Union. It
details registration obligations of manufactures and suppliers to assure compliance.
The shape, surface and design of our products (articles) are paramount to the chemical composition.
LYN-TRON products are deemed articles, as defined in the REACH Directive.
Articles are exempt from REACH unless they release a SVHC (Substance of Very High Concern) as
identified in the regulation.

Lyn-Tron, Inc. does not manufacture or distribute any products that contain these substances.
No chemicals or substances are intentionally released from Lyn-Tron’s products.

Lyn-tron, Inc. products are Halogen free.

For these reasons, Lyn-Tron products are considered articles that are not affected by the
REACH Directive. They do not require registration. -- Paragraph 32 and Chapter 2 (3.3)

Sincerely,

Michael E. Quinn
Exec Vice President

Lyn-Tron Reach Statement
• Company Header
• Appropriate individual
• Date is current
• Inaccurate understanding of REACH
responsibilities


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Momentive SVHC – RTV167 2012-01-16
• Company Header
• Appropriate individual
• Includes appropriate regulatory reference
• Date is current


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 SVHCs – MORE TO COME
• A commitment to have 136 SVHCs by the end of 2012 was communicated in March 2010 by
Janez Potocnik, EU Environmental Commissioner, and Antonio Tajani, EU Industry and Enterprise
Commissioner.
• This commitment was nonbinding and it has come to light that this is unattainable
»» Various reasons including budgetary pressures and a closer review of the substances
• The new target of the European Commission is to have 15 substances added to the candi-
date list by the end of 2012.
»» 13 were just added
»» 4 consolidated down to 2
»» This brings the current total to 84
»» A few others are actually expected in August but the latest likely addition timeline is
by December in following the example of previous years
»» 13 substances have a 2012 expected date of submission which means a possible
97 by the end of this year


AS SENTCOM PLIANCE

 SVHC Candidate List
Registry of Intentions
22 Registered
• 5 have been on the list since 2008 and have no expected date of submission

Expected
Notification
Substance name EC no. CAS no. date of Uses
of intention
submission
• Man-made fluorosurfactant and global pollutant.

• Perfluorooctanesulfonic acid is usually used as the sodium or
potassium salts.

• PFOS was the key ingredient in Scotchgard, a fabric protector
made by 3M, and numerous stain repellents.

• PFOS, together with PFOA, has also been used to make aque-
ous film forming foam (AFFF), a component of fire-fighting
foams, and alcohol-type concentrate foams.

• PFOS compounds can be also found in some impregnation
Perfluorooctanic acid agents for textiles, paper, and leather; in wax, polishes, paints,
206-397-9 335-67-1 16112011 28012013
(PFOA) varnishes, and cleaning products for general use; in metal sur-
faces, and carpets.

• In the semiconductor industry, PFOS is used in multiple
photolithographic chemicals including: photoacid generators
(PAGs) and anti-reflective coatings (ARCs). It has been phased
out in the European Union semiconductor industry due to
health concerns.

• In Skydrol, a hydraulic fluid used in commercial aviation.

• The most important emission sources of PFOS are metal plat-
ing and fire-fighting foams.


AS SENTCOM PLIANCE

Expected
Notification
of intention
submission
• Derivative of PFAO

• A surfactant used primarily as an aid in processing various
fluoropolymers.

• Ammonium perfluorooctanoate–also called APFO, PFOA, or
C8–is a surfactant associated with the production of Teflon®.

• It has been used in thousands of applications over the past 50
years. Some of these applications include its use in fire-fighting
foams and as an inert ingredient in pesticides.

• APFO may also be formed from the microbial degradation of
Ammoniumpentade- grease-resistant coatings applied to items such as pizza boxes
223-320-4 3825-26-1 16112011 28012013
cafluorootanoate (APFO) (Fluoridealert)

• This microbial degradation is suspected as the reason higher
levels of APFO have been recorded in wastewater effluents than
influents.

• One of the chemicals known to breakdown into APFO is
Zonyl® (Gruenberg, 2005). Zonyl® is used widely in the paper
industry in items such as linerboard, folding cartons, bags, fast
food wrappers, trays, and pet food liners. Zonyl® is also the
chemical used in Stainmaster® carpets and fabrics. All ofthese
products have the potential to break down into APFO and
cause problems at wastewater treatment facilities.


AS SENTCOM PLIANCE

Expected
Notification
of intention
submission
• Phthalates are one of the most produced chemical groups
with an annual production of several million tonnes per year.
Phthalates are used as plasticisers (softeners) in plastics and
PVC products, and also as solvents and fragrance carriers in
Diisopentylphthalate 210-088-4 605-50-5 19042011 30072012 personal care products and cosmetics.

• The use of phthalates has increased dramatically during the last
50 years and they are now found virtually everywhere in all
kinds of products. Among many other items, phthalates can be
found in carpets, flooring, toys, clothes, wallpapers, water pipes,
paints, furniture, perfumes, cosmetics, cables and electronics.

• Phthalates are not chemically bound to plastic materials so they
can easily migrate into air, water, dust and humans. Therefore,
exposure to phthalates is inevitable both for humans and for the
environment.
Di-n-pentyl phthalate 205-017-9 131-18-0 9112011 30012013
• The use of phthalates has increased dramatically during the last
50 years and they are now found virtually everywhere in all
kinds of products. Among many other items, phthalates can be
found in carpets, flooring, toys, clothes, wallpapers, water pipes,
paints, furniture, perfumes, cosmetics, cables and electronics.


AS SENTCOM PLIANCE

Expected
Notification
of intention
submission

Distillates (coal tar), heavy oils 292-607-4 90640-86-1 27062008

• The destructive distillation of bituminous coal produces ‘coal
tar pitch’ a Volatile organic compound (CTPV) which contains
Distillates (coal tar), heavy a wide variety of polycyclic aromatic hydrocarbons (PAH’s).
295-304-5 91995-42-5 27062008
oils, pyrene fraction
• PAHs occur in oil, coal, and tar deposits, and are produced
as byproducts of fuel burning (whether fossil fuel or biomass).

Distillates (coal tar), pitch,
295-313-4 91995-52-7 27062008
pyrene fraction

Residues (coal tar), pitch distn. 295-507-9 92061-94-4 27062008


AS SENTCOM PLIANCE

Expected
Notification
of intention
submission
• Pure inorganic arsenic is a gray-colored metal, but inorganic
arsenic is usually found combined with other elements such as
oxygen, chlorine, and sulfur

• Arsenic combined with elements such as oxygen, chlorine, and
sulfur forms inorganic arsenic; inorganic arsenic compounds
include arsenic pentoxide, arsenic trioxide, and arsenic acid.
Arsenic combined with carbon and hydrogen forms organic
arsenic; organic arsenic compounds include arsanilic acid, ar-
Further Arsenic compounds - - 30042008 senobetaine, and dimethylarsinic acid.

• The major use for inorganic arsenic is in wood preservation;
arsine is used in the microelectronics industry and in semicon-
ductor manufacture.

• Until the 1940s, inorganic arsenic solutions were widely used
in the treatment of various diseases, such as syphillis and pso-
riasis. Inorganic arsenic is still used as an antiparasitic agent in
veterinary medicine and in homeopathic and folk remedies in
the United States and other countries.


AS SENTCOM PLIANCE

Expected
Notification
of intention
submission

• Phthalic Anhydride is mainly used as a hardener for epoxy resins and as
intermediate for plasticizers, specialty resins, insect repellents and rust
inhibitors. Preferred Acronym for 25550-51-0 is MHHPA.

• MHHPA is a curing agent for epoxy resin mainly used in electric and
electronics field. With the many advantages, e.g. low melting point, low
viscosity of the resin system; long pot life, high heat resistance of the
cured material and excellent electrical properties at high temperature.
MHHPA is widely used in impregnating electrical coils, casting elec-
tricity components and sealing semiconductors, e.g. outdoor insulators,
capacitors, light emitting diodes and digital displays.
Hexahydromethylphathalic
• 19438-60-9 is also identified as MHHPA or 4-MHHPA:
anhydride, 247-094-1, 25550-51-0,
Hexahydro-4-methylphathalic
• 1. As solidifying agent for epoxy resins: MHHPA is heating-solidifi-
anhydride, 243-072-0, 19438-60-9,
25052012 06082012 cation type acid anhydride solidifying agent, mainly used in electri-
Hexahydro-1-methylphathalic 256-356-4, 48122-14-1,
anhydride, cal and electronic field, with low melting point, the compounding
Hexahydro-3-methylphathalic 260-566-1 57110-29-9 matter with alicyclic epoxy resin is of low viscosity, long use life,
anhydride excellent heat resistance and high-temperature electric properties,
can be used in dipping of coil of electric apparatus, casting of electric
parts and sealing of semiconductor.

• 2. As adhesive: the alicyclic epoxy adhesive made from MHHPA
has similar refractive index as optical glass, low internal stress after
solidifying, high adhesion strength, color unchangeable, resistance to
aging, applicable for cohering large-area optical parts.

• 3. As insecticide, plasticizer and antirust, etc.

• 57110-29-9: Listed generally as an epoxy resin compositions for sealing
semiconductor devices.


AS SENTCOM PLIANCE

Expected
Notification
of intention
submission

Cyclohexane-1,2- • HHPA - This product is used in coatings, epoxy resin solidify-
201-604-9 85-42-7 25052012 06082012
dicarboxylic anhydride ing agents, polyester resins, adhesives and plasticizing agents,etc.

• PFTA - (Perfluorotetradecanoic acid)
• Chemical Class:
• Perfluorochemical (PFC)
• Chemical SubClass:
Heptacosafluorotetradecanoic
206-803-4 376-06-7 24042012 06082012 • Perfluorinated carboxylic acid
acid
• PFCs are industrial chemicals widely used as water, stain and
grease repellants for food wrap, carpet, furniture, and clothing.
The family includes such well-known name brands as Scotchgard
and Teflon. (SEE PFOA and APFO)

Pentacosafluorotridecanoic
276-745-2 72629-94-8 24042012 06082012 • Also falls under the PFC chemical class.
acid

Henicosafluoroundecanoic • PFUnA (Perfluoroundecanoic acid)
218-165-4 2058-94-8 24042012 06082012
acid • Also falls under the PFC chemical class.


AS SENTCOM PLIANCE

Expected
Notification
of intention
submission

• PFDoA (Perfluorododecanoic acid)
• Also falls under the PFC chemical class.
• Trade and Product Names associated:
• Algoflon, Centennial Cloth, Clear-Shield, DWR, Dyneon,
Excel, Extragard DN 100-1, Extreme Superpruf, Fiber
Shield, Forafac, GapShield, MysticMaid Corazza, Polyflon,
Tricosafluorododecanoic Scotchguard, Silverstone, Stain-Guard, Staindefender,
206-203-2 307-55-1 24042012 06082012 Stainmaster, SurfTechs 4300, SurfTechs 4301, SurfTechs 4302,
acid
Teflon, Zepel, Zonyl
• Possible breakdown product of, or manufacturing intermediate
of commercial perfluorochemicals (PFCs), uses of PFCs include
stain/water/oil repellent fabric protector, water/oil repellent pa-
per coating, wiper blades, bike chain lubricant, wire and cable
insulation, pharmeceutical packaging, engine oil additive, nail
polish, hair curling and straightening


AS SENTCOM PLIANCE

Expected
Notification
of intention
submission

• Cadmium and its compounds are already restricted under
Annex XVII as a colorant, as a stabiliser, for cadmium-plating
in specific instances. These will be covered in an upcoming slide.
• Cadmium has many common industrial uses as it is a key com-
ponent in battery production, is present in cadmium pigments,
coatings, and is commonly used in electroplating.
• Cadmium oxide is used in black and white television phosphors
and in the blue and green phosphors for color television picture
tubes. Cadmium sulfide (CdS) is used as a photoconductive
surface coating for photocopier drums.
• In paint pigments, cadmium forms various salts, with CdS be-
ing the most common. This sulfide is used as a yellow pigment.
Cadmium selenide can be used as red pigment, commonly
called cadmium red. To painters who work with the pigment,
cadmium yellows, oranges, and reds are the most brilliant and
Cadmium 231-152-8 7440-43-9 18042012 06082012 long-lasting colors to use. In fact, during production, these col-
ors are significantly toned down before they are ground with
oils and binders, or blended into watercolors, gouaches, acryl-
ics, and other paint and pigment formulations. Since these pig-
ments are potentially toxic, it is recommended to use a barrier
cream on the hands to prevent absorption through the skin
when working with them even though the amount of cadmium
absorbed into the body through the skin is usually reported to
be less than 1%.
• In PVC, cadmium was used as heat, light, and weathering sta-
bilizers. Currently, cadmium stabilizers have been completely
replaced with barium-zinc, calcium-zinc and organo-tin stabi-
lizers. Cadmium is used in many kinds of solder and bearing
alloys, due to a low coefficient of friction and fatigue resistance.
It is also found in some of the lowest-melting alloys, such as
Wood’s metal.


AS SENTCOM PLIANCE

Expected
Notification
of intention
submission

• As a compound that is easy to isolate and purify, it is the princi-
pal source of cadmium for all commercial applications.
• CdS is known as cadmium yellow (CI pigment yellow 37). By
adding varying amounts of selenium as selenide, it is possible to
obtain a range of colors, for example CI pigment orange 20 and
Cadmium sulphide 215-147-8 1306-23-6 18042012 28012013
CI pigment red 108.
• Synthetic cadmium pigments based on cadmium sulfide are
valued for their good thermal stability, light and weather fast-
ness, chemical resistance and high opacity.
• CdS is used as pigment in plastics.

• Cadmium oxide is used in cadmium plating baths, electrodes
for storage batteries, cadmium salts, catalyst, ceramic glazes,
Cadmium oxide 215-146-2 1306-19-0 18042012 06082012
phosphors, and nematocide. Major uses for cadmium oxide are
as an ingredient for electroplating baths, and in pigments.

• Methoxy acetic acid (MAA) is widely used as a solvent in the
manufacture of protective coatings such as lacquers, enamels,
phenolic varnishes and alkyl resins. MAA is also used as an in-
termediate chemical for the production of ethylene glycolm-
Methoxy acetic acid 210-894-6 625-45-6 18042012 06082012
onomethyl ether (EGME), a common plasticiser used by paint,
printing, textile and leather industries. Used in the manufactur-
ing of plant protecting agents and pharmaceuticals.
• Also as a flotation adjuvant.


AS SENTCOM PLIANCE

Expected
Notification
of intention
submission

• Phthalate chemical class – plasticizers are the main function –
N-pentyl-isopentylphtalate – – 27022012 06082012
see earlier phthalates in table.

• Related to phthalates, also used as a plasticizer.
1,2-Benzenedicarboxylic
acid, dipentylester, branched 284-032-2 84777-06-0 27022012 06082012 • Not to be mistaken with 1,2-Benzenedicarboxylic acid, di-
and linear C7,11-branched and linear alkyl esters (DHNUP) CAS
Number 68515-42-4 although both are plasticizers.

• More commonly known as Azodicarbonamide.
• One of most widely used chemical foaming agents.
Diazene-1,2-dicarboxamide • This product is widely used in polyvinyl chloride, polyethyl-
(C,C’-azodi(formamide)) 204-650-8 123-77-3 22062012 06082012 ene, polypropylene, ABS resin and rubber foam. Food Grade
Application: used in food industry as a food additive, a flour
bleaching agent and improving agent.


AS SENTCOM PLIANCE

Most Common Uses for the intended SVHCs
Further Arsenic Compounds
• Furniture Industry (wood preservation)
• Microelectronics Industry
• Semiconductor Industry
• Veterinary and homeopathic applications (antiparasitic agent)

Coal Tar Distillates and Residues
• Fuel, Oil Industries


AS SENTCOM PLIANCE

PFOA
• Previously fabric protection and stain repellents - key ingredient
• Metal plating
• Fire-fighting foams
• Semiconductor Industry – phased out in the EU
• Aviation industry (hydraulic fluid)
• Consumer products (impregnation agent)
• textiles, paper, and leather; in wax, polishes, paints, varnishes, and cleaning products for
general use

APFO
• Formed from the microbial degradation of grease-resistant coatings applied to items such as pizza boxes
• One of the chemicals known to breakdown into APFO is Zonyl®
• Paper industry
»» linerboard, folding cartons, bags, fast food wrappers, trays, and pet food liners.
• Stainmaster® carpets and fabrics.


AS SENTCOM PLIANCE

Heptacosafluorotetradecanoic acid /
Pentacosafluorotridecanoic acid /
Henicosafluoroundecanoic acid /
Tricosafluorododecanoic acid
• PFCs
• Industrial chemicals widely used as water, stain and grease repellants for
»» Food wrap
»» Carpet
»» Furniture
»» Clothing
• Includes such well-known name brands as Scotchgard and Teflon.


AS SENTCOM PLIANCE

Diisopentylphthalate / Di-n-pentylphtalate
N-pentyl-isopentylphtalate /
1,2-Benzenedicarboxylic acid, dipentylester, branched and linear
• Multi-Industry Impact - Plasticizers
• carpets, flooring, toys, clothes, wallpapers, water pipes, paints, furniture, perfumes, cosmetics,
cables and electronics

Hexahydromethylphathalic anhydride /
Hexahydro-4-methylphathalic anhydride /
Hexahydro-1-methylphathalic anhydride /
Hexahydro-3-methylphathalic anhydride (MHPPAs)
• Electric and electronics Industries
• Semiconductor Industry


AS SENTCOM PLIANCE

Cyclohexane-1,2-dicarboxylic anhydride
• Multi-Industry Impact
• Used in coatings, epoxy resin solidifying agents, polyester resins, adhesives and plasticizing
agents,etc

Diazene-1,2-dicarboxamide (C,C’-azodi(formamide))
• Multi-Industry Impact
• Widely used in:
• polyvinyl chloride
• polyethylene
• polypropylene
• ABS resin
• rubber foam

• Food Grade Application: used in food industry as a food additive, a flour bleaching agent and
improving agent.


AS SENTCOM PLIANCE

Methoxy acetic acid (MAA)
• Protective Coatings
• Intermediate for EGME – plasiticizer = Multi-Industry Impact
• Paint
• Printing
• Testile
• Leather
• Plant protection
• Pharmaceuticals


AS SENTCOM PLIANCE

Cadmium / Cadmium Sulphide / Cadmium Oxide
• Colorant, Stabilizer, Plating
• See Next Slide for existing EU Restriction under REACH

Non-EU Uses Listed:
• Battery Industry
• Pigments, Paints, Colorants
• Solder and Bearing Alloys
• Electroplating


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