Bisphenol-A and SVHC

November 3, 2016 • Posted in Technical

As I write this post, it is close to Halloween. So, in the spirit of things…

There is a legitimate possibility that Bisphenol-A will be added to the Candidate List of Substances of Very High Concern (SVHC) in the European Union. (SVHC is the portion of REACH legislation that affects the thermoplastic industry the most; REACH is an acronym for “Registration, Evaluation and Authorisation of Chemicals” that governs the EU.)

Boo! Have I scared you?

Now, on the surface, this might seem like something to be completely frightened about. After all, Bisphenol-A is a main building block of polycarbonate and some epoxy resins. Some end-use products containing Bisphenol-A-based resins include DVDs and Blu-Rays, optical lenses for eyeware, medical equipment and linings for cans.

France recently submitted their concerns about Bisphenol-A being toxic for reproduction to ECHA (the governing body of REACH), and public consultation on this subject closed in mid-October, with a decision expected to be reached in mid-December. (France supposedly is also ready to submit Bisphenol-A to be included on the Candidate List as an endocrine disruptor.)

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So what does this mean? Will polycarbonate be banned in the EU? Will I never be able to get my hard-to-find Blu-Ray 3D movies from resellers on Ebay? (Okay, I’m a techno geek… and proud of it.)

It turns out that reality is much less scary than the unknown. According to the European Information Centre on Bisphenol-A, the chemical is used as an intermediate – that is, a building block – to manufacture polymeric materials. Since intermediate uses are exempt from REACH authorization, there is not expected to be a direct impact should Bisphenol-A be added to the Candidate List of SVHC. (Remember: there’s only been a public consultation period that closed in mid-October. This does not mean that Bisphenol-A is definitely being added to the Candidate List in December.)

We do, however, anticipate an influx of questions regarding the presence of residual monomer in polycarbonate resins that M. Holland distributes. We will be working with the manufacturers of these resins to have statements ready to distribute, should Bisphenol-A be added to the Candidate List in December. (We would ask customers to understand that some resin manufacturers consider this information to be a trade secret.) Likewise, we will work with all our suppliers to have updated SVHC compliance statements as soon as possible following the announcement of the additions

At least in the States, we’ve faced a similar scare already – specifically, Bisphenol-A is listed in California’s Proposition 65 legislation. (Prop 65 is a listing of chemicals that have been declared by the state of California to be known to cause cancer – and this listing proved to be controversial.) The difference, though, is that Prop 65 does not outright stop someone from using a listed chemical; SVHC does limit how much can be manufactured, used or imported into the European Union.

Whether there are reasons to be concerned over health issues is as polar of a topic as the presidential election right now. On both sides are passionate individuals and groups with plenty of evidence showing that Bisphenol-A is either safe or dangerous to humans. In the United States, although Bisphenol-A has been removed from products designed for children three and under, it has been declared by such bodies as the Food & Drug Administration, Health Canada, and the European Food Safety Authority that, as long as it is used as intended, there is no human health concern from Bisphenol-A.

Are there specific regulatory issues you’d like to see covered in future blog posts? If so, please e-mail me at:

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M. Holland VP Corporate Development Dwight Morgan Addresses the Challenges of International Business in Plante Moran WBBM Roundtable
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