On May 3, 2011, the EU environmental group, the International Chemical Secretariat (ChemSec), announced the addition of 22 chemicals to its so-called “Substitute It Now!” list or “SIN List.” ChemSec supposedly selected the chemicals based “solely” on their endocrine disrupting properties. Although there is no established EU definition for what constitutes an endocrine disrupting chemical (EDC), according to the USEPA and the NRDC, an endocrine disruptor is a synthetic chemical that, upon absorption into the body, either mimics or blocks hormones and disrupts the body’s normal functions. According to ChemSec’s press release, EDCs “interfere with our hormone system and have been increasingly linked to a range of health problems including cancer, diabetes, behavioural and attention deficit disorders, as well as impaired fertility.” The group added the chemicals in part to force EU regulators to begin selecting EDCs for the authorization process set out in the EU’s primary chemical control law, titled “Registration, Evaluation, Authorisation, and Restriction of Chemicals” (REACh).
The SIN List is an inventory of chemicals that ChemSec developed. Chemicals on the list purportedly meet the Substance of Very High Concern (SVHC) criteria established under REACh. SVHCs are those chemicals that may be especially harmful to human health or the environment and thus may be considered for the REACH authorization process, which contemplates substitution of such chemicals for those that are “safer.” ChemSec developed the list to encourage early substitution and to suggest “candidates” for authorization.
According to ChemSec, many of the 22 chemicals are “commonly found in toys, food packaging, and cosmetics….” The chemicals that ChemSec selected are:
- 3-benzylidene camphor
- 4-methylbenzylidene camphor
- Dicyclohexyl phthalate (DCHP)
- Diethyl phthalate (DEP)
- Dihexyl phthalate (DHP)
- Ethylhexyl methoxycinnamate
- Metam natrium
- Methyl tertiary butyl ether (MTBE)
Thus far, the European Commission has embraced the SIN List and its recent additions. On May 19, 2011, in his opening speech at the annual Helsinki Chemicals Forum, Janez Potocnik, European Commissioner for Environment, said “The recently published second edition of the SIN list, which also includes substances with endocrine disrupting properties, should indicate to you the substances the European Commission will take into consideration for placement on the candidate list.” Potocnik also referred to the European Commission’s goal that another 90 substances should be added to the Candidate List for Authorization by the end of next year: “Now that we are working at full speed getting 136 substances of very high concern on the REACh candidate list by 2012, and even more by 2020, the dream of green chemistry is becoming a reality.”
Companies manufacturing, importing, or using chemicals in the EU will undoubtedly take seriously Mr. Potocnik’s remarks. Moreover, they are certain to continue monitoring the SIN List and consider its potential implications when making product and raw material selections.