SIN (Substitute It Now!) List

The SIN (Substitute It Now!) List is a database developed by the International Chemical Secretariat (ChemSec) of chemicals the uses of which are likely to become legally restricted under EU REACH regulation. The list is being used by public interest groups as a campaign tool to advocate for increasing the pace of implementation of REACH and by commercial interests to identify substances for control in chemicals management programmes. [1]

History and development

The SIN List is composed of chemicals evaluated by the environmental NGO ChemSec as meeting EU criteria for being Substances of Very High Concern (SVHCs) under Article 57 of REACH, being either carcinogenic, mutagenic or reprotoxic (CMR), persistent, bioaccumulative and toxic (PBT), very persistent and very bioaccumulative (vPvB), or posing an equivalent environmental or health threat.,[1][2]

The first SIN List, known as version 1.0, was published in 2008 and identified 267 chemicals as meeting the Article 57 criteria for being SVHCs. ChemSec's assessment was independently validated by the Technical University of Denmark.[3]

In 2009 a further 89 substances were added to the SIN List (Version 1.1),[4] before in 2011 another 22 chemicals were added (Version 2.0)[5] for fulfilling the REACH 57(f) criterion of equivalent concern as endocrine disrupting chemicals (EDCs). The 2011 EDC additions were made in consultation with TEDX, the US endocrine-disruption research NGO founded by Professor Theo Colborn, and coincided with EU plans over 2011–2012 to develop accepted criteria for identifying endocrine disrupting chemicals.[6]

In October 2014, the list was updated, this time with 28 new chemicals. With this update, the SIN List was also divided into 31 groups, and a tool for sustainable substitution based on the SIN List – SINimilarity – was presented.[7]

SIN List Advisory Committee

The development of the SIN List is guided by a nine-member NGO advisory committee:[8]

Impact

EU Legislation

The disparity between the length of the SIN List in comparison to the 15 chemicals nominated by the EU as SVHCs in October 2008 was used to pressure the European regulatory authorities and Member States to accelerate the nomination process.[9] In 2011 Members of the European Parliament's Environment Committee cited the SIN List in criticising the European Commission for continuing slow progress on EDCs and evaluation of safety of chemicals in mixtures.[10]

EU regulators have been cautiously welcoming of the SIN List. Margot Wallström, Vice-President of the European Commission, stated that she welcomed initiatives such as the SIN List “[which] draw the attention of the public and industry to the most hazardous chemicals that should be a priority for inclusion in the REACH authorisation procedure”.[11] European Commissioner for the Environment Janez Potočnik has referred to the SIN list as “[indicating] the substances the European Commission will take into consideration for placement on the candidate list.[12] Industry representative group CEFIC has criticised the publication of the list for occurring outside the legal design of REACH.[13]

Commercial substitution

Sony Ericsson, Sara Lee, Skanska,[14] Marks & Spencer,[15] Dell[16] and Carrefour[17] are on record as referring to the SIN List in their chemical substitution programmes. The SIN List is also used by other public interest groups in lobbying companies to substitute or phase out hazardous chemicals.[18]

Socially Responsible Investment

The potential for legal restrictions on chemical use increasing costs associated with reformulating products and modifying processes has resulted in SIN List data being used by investment analysis firms concerned with Socially Responsible Investment, to aid in calculating financial risk posed by companies’ sustainability profiles.[18][19]

In March 2013 ChemSec published the SIN Producers List, a list of the 709 companies manufacturing or importing SIN List substances in the EU. The list is derived from data presented in the European Chemicals Agency (ECHA) database of registered substances.[20]

ChemSec has together with ClientEarth requested information about producers of REACH registered substances to be made publicly available, and launched a lawsuit against the European Chemicals Agency on this issue in 2011.[21]

  • Comprehensive SIN List methodology
  • SIN 2.0 (Endocrine Disruptors) Methodology
  • Summary of the SIN List for the public
  • REACH Article 57: THE EUROPEAN PARLIAMENT AND THE COUNCIL OF THE EUROPEAN UNION, (2006). REGULATION (EC) No 1907/2006 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 18 December 2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), establishing a European Chemicals Agency, amending Directive 1999/45/EC and repealing Council Regulation (EEC) No 793/93 and Commission Regulation (EC) No 1488/94 as well as Council Directive 76/769/EEC and Commission Directives 91/155/EEC, 93/67/EEC, 93/105/EC and 2000/21/EC. Official Journal of the European Union. p. 396/142 (PDF, English)

References
  1. SIN List 2.1 update: new information from REACH registrations extends the SIN List
  2. ChemSec, (2008). Methodology for selection of substances included in the REACH SIN* List 1.0 (*Substitute It Now) (PDF)
  3. Eriksson E. H-C Holten-Lützhøft & A Ledin, (2009) Second opinion on the hazards associated with the substances selected for the REACH SIN* List 1.0. Technical University of Denmark. Denmark. (PDF)
  4. ChemSec (2009) The SIN List updated with substances newly classified within the EU – now containing 356 substances
  5. ChemSec (2011) 22 New SIN Substances(PDF)
  6. European Commission DG Environment, (2011). 4th Report on the implementation of the "Community Strategy for Endocrine Disrupters" a range of substances suspected of interfering with the hormone systems of humans and wildlife (COM (1999) 706). Brussels, Belgium. (PDF)
  7. ChemSec. SIN List updated and new tool, SINimilarity, launched Retrieved 08/10/14
  8. ChemSec. "The NGOs Behind the SIN List". Retrieved 30 November 2011.
  9. ChemSec. "Boosting Regulatory Processes". Retrieved 30 November 2011.
  10. Chemical Watch. "MEPs pressure EU Commission on EDCs, cocktail effect". Retrieved 30 November 2011.
  11. Wallström, Margot. "We have the legislation - now it's time to make it work". Retrieved 30 November 2011.
  12. Potočnik, Janez. "Reaching for resource efficiency and innovation in the chemicals sector". EU DG Environment. Retrieved 30 November 2011.
  13. ICIS.com. "Firms should ignore confusing 'SIN' list - Cefic". Retrieved 30 November 2011.
  14. ChemSec. "Protecting Consumers and the Environment" (PDF). Retrieved 30 November 2011.
  15. ChemSec. "Consumer's "right to know" tested - companies asked if they use any SIN List chemicals". Retrieved 30 November 2011.
  16. Chemical Watch (2009). "Dell strives to get ahead of the regulatory curve". Retrieved 30 November 2011.
  17. Chemical Watch (February 2009). "Retailers integrate REACH into chemicals management". Retrieved 30 November 2011.
  18. Chemical Watch (5 October 2011). "Consumer NGO says retailers still failing on SVHC disclosure". Retrieved 30 November 2011.
  19. "Dangerous chemicals list sparks concern for investors". Environmental FInance. 12 May 2011. Archived from the original on 2012-04-14. Retrieved 30 November 2011.
  20. "ChemSec publishes SIN list registrants". Chemical Watch. 5 March 2013. Retrieved 13 March 2013.
  21. "ECHA publishes registrants' names and registration numbers". Chemical Watch. 28 November 2012. Retrieved 13 March 2013.
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