Syensqo relies on a list of SVHC that contains all substances that are Carcinogenic, Mutagenic or toxic to Reproduction (CMR 1a and 1b), Persistent, Bioaccumulative and Toxic (PBT) or very Persistent and very Bioaccumulative (vPvB), Identified as causing probable serious effects to Human Health or the Environment.

S-SVHC do not include all dangerous substances, since non SVHC may nevertheless present dangerous properties for health or the environment (due to their acute toxicity properties for example ex hydrogen fluoride)

The inventory of SVHC and the impact in terms of risk assessment and control shall have to be performed for Products put on the market, within 2 years following the acquisition.

Syensqo’s SVHC list (S-SVHCs) includes all substances worldwide which must be considered as SVHC. This list is then used as a check to inventory substances in Syensqo’s activities. The list contains substances that are either

• Carcinogenic, Mutagenic or toxic to Reproduction (CMR),
• Persistent, Bioaccumulative and Toxic (PBT) or very Persistent and very Bioaccumulative (vPvB),
• Identified as causing probable serious effects to Human Health or the Environment.

Some new criteria may be added progressively, for example in the context of the EU Chemical Strategy for Sustainability.

This SRA list (Substances Requiring Attention ) includes substances alleged to cause effects to human health or environment which are not SVHCs as defined in the black and red categories but that require specific attention, considering interrogations or suspicions from the community on their hazard properties or potential effects.

The S-SVHC List results from the consolidation of external official and non-official lists from geographical zones. Syensqo experts may add additional substances according a defined process (chapter 4.2.2 of the framework procedure IND-HSE-12-PRO).

Substances are added or removed from the S-SVHC list by HSE experts or other experts committees only after formal review between the requestor, HSE-PRA/PS-TERA, the Product Stewards of GBU, during a meeting of the SVHC-AT.

There are currently several thousand of substances in the S-SHVC/SRA reference list

Remark : these figures relate to the total number of substances that are to be considered as SVHC by Syensqo. Inventories are necessary to determine, amongst these global lists, which substances concern Syensqo'sactivities.

 The S-SVHC/SRA list is generally updated once/year. A column in the table indicates which lines have been modified.

S-SVHC/SRA substances are categorized (black, red and yellow) to alert GBUs on their regulatory status and the short / medium / long term potential criticality in term of business activities.

The black list contains the substances already in a legal or regulatory process of phasing-out or restriction with a known deadline in at least a given country or zone.

The red list contains substances currently included in legal or regulatory lists which in the medium term could enter a process of authorization or restriction and therefore become part of the black list.

Substances alleged to cause effects to human health or environment, but which are not SVHCs, belong to the yellow list: They require specific attention considering interrogations or suspicions from the community on their current hazard properties or their potential effects.

No, only officially adopted lists are included it in the reference list. Anyway, separately, information on drafts publication is provided by PRAS/PS team to all people concerned.

In case of new regulatory requirements (new classification,...) with a specific application date, the update in Syensqo SVHC/SRA list will be done before this new requirement becomes applicable.

 The same S-SVHC list may be used worldwide for Product Safety or Environment domains.

 Syensqo’s operational entities must establish inventories of the substances contained in their marketed products.

SRA must be considered when establishing inventories related to Marketed Products.

Tracking yellow substances (or products containing yellow substances) put on the market or released in the environment is required, to alert GBUs on potential concern related to the impact on business activities and therefore to anticipate the defense of the substance and to raise awareness about new regulatory development during R&I projects and new product developments. For marketed products being or containing yellow substances, it is the responsibility of the GBU to decide its strategy of risk management.

Procedures and documents related to Syensqo SVHC/SRA are available on the Syensqo SVHCs web pages.

 You should contact Sandra Saez (legal for industrial affairs) who will coordinate with the global legal network in order to provide a sounded answer to you query. Thanks to copy Patricia Villers if this is a transversal issue