Helsinki Chemicals Forum 2017 Stakeholder views on hot topics in chemicals safety

Welcome to this report on the debates held at the ninth

annual Helsinki Chemicals Forum. This year’s event

attracted 189 delegates from 39 countries. The 2017

Forum discussion on five key themes ranged from the

role chemicals safety plays in the UN’s sustainable

development goals (SDGs) to how substances of very

high concern (SVHCs) are managed in products in

a free trade world. The Helsinki think tank addressed

the changing global political landscape, as well as

the increasing challenges we face protecting the

environment and human health, while putting forward

the case for the safe management of chemicals.

With a number of significant anniversaries, most

notably it being ten years since the EU’s REACH

Regulation entered into force, the two-day forum

kicked off by looking at what chemicals legislation

has achieved over the last decade. Following this

reflective theme, topics moved to the future, asking

what the business case is for the UN’s SDGs that were

adopted in 2015. Further panels covered the post-

2020 global chemicals supply chain, asking what will

be the drivers for market supply and demand and will

chemicals product safety emerge a winner or loser.

It also addressed the need to speed up chemicals

assessments and closed on the theme of SVHCs

in products and whose job is it to control these

in a free trade world?

This report is prepared by independent news service

Chemical Watch and aims to be a balanced and

accessible reflection of two days of debate in order

to further understanding. We have not taken sides,

or judged comments on their accuracy, veracity

or fairness.

This is not a formal report because this annual forum

is not an official session and its conclusions do not

represent a consensus. Instead, this report offers

a reference point for policymakers, companies,

academics and others – presenting the voice of the

people in the room at this key annual gathering about

the important topics discussed. On the last pages of

the report we provide an unedited selection of virtual

comments and questions that were posted on the

forum message wall to ensure that audience views

are reflected.

Mamta Patel

CEO, Chemical Watch

Luke Buxton

Europe Editor, Chemical Watch

Leigh Stringer

Global Business Editor, Chemical Watch

Panel 1: What has chemicals legislation done for us over the last decade?

Panel 2: The sustainable development goals – is there a business case?

Panel 3: Post-2020 global chemicals supply chains – what will be the drivers for market supply and demand and will chemicals product safety emerge a winner or loser?

Panel 4: Speeding up chemicals assessments – from novel information to new management approaches, what works?

Panel 5: Substances of concern (SVHCs) in products – whose job is it to control these in a free trade world?

Writing on the wall: An unedited selection of comments posted to the message wall by the audience

Helsinki Chemicals Forumwww.helsinkicf.eu

Chemicals Forum AssociationMessuaukio 1, 00521 Helsinki, Finland

Hannu VornamoSecretary general

+ 358 40 500 4785hannu.vornamo@elisanet.fi

Tarja GordienkoCommunications manager

+358 50 584 7262tarja.gordienko@messukeskus.com

Ida ÅgrenProject assistant

+358 40 450 3181ida.agren@messukeskus.com

Chemical Watch contacts

Mamta PatelCEO

+44 (0) 203 603 2110mamta.patel@chemicalwatch.com

Leigh StringerGlobal business editor

+44 (0) 203 603 2119leigh.stringer@chemicalwatch.com

Luke BuxtonEurope editor

+44 (0) 203 637 5793luke.buxton@chemicalwatch.com

Helsinki Chemicals Forum contacts

Contents

ALL PH

OTO

S © M

essukeskus Helsinki

Panel Debate 1:

What has chemicals legislation done for us over the last decade?

Chemicals legislation

Key issues

• Some REACH registration dossiers are inadequate

in terms of poor or insufficient data

• Even so, more information is now far more accessible.

The question is how will the wealth of information

be used?

• Improvements to REACH are needed – it is too slow,

too scientific and too detailed

• In particular, REACH authorisation and restriction

processes are not perfect and need improving –

debate continues around which regulatory measure

should be used for certain substances/circumstances

• Regulatory and industry efforts on ‘emerging’ issues,

such as nanomaterials and endocrine disrupting

chemicals, need to speed up

• A better interface is needed between REACH and other

EU legislation, such as that dealing with occupational

health and waste

• More substances need to be added to the authorisation

list – they currently average about three per year

• NGOs and authorities say REACH can stimulate

competition and innovation, while some industry

players say this is not necessarily the case

• While there are now comparable REACH enforcement

projects in different member states, the level

of enforcement is still an important issue

• Questions remain on how to achieve and manage

an effective circular economy when some products

contain hazardous substances

• Global mutual acceptance of data remains a major

challenge and this reluctance is a barrier to faster

regulatory action on hazardous chemicals

Achievements

• Chemicals legislation, particularly REACH,

has closed the information gap on substances

• There is better communication between

industry players

• There is now better information for downstream users

What more can be done?

• Echa can learn from the experiences of regulating

authorities in countries like Canada and vice versa

• Current processes for REACH restriction and

authorisation need to be improved

• Regulators need to be braver and take more

risks to achieve clearer outcomes more quickly

• Regulations need to be more pragmatic

Mood in the room – key take-home messages

• There is a need for more efficient processes

• REACH is not perfect but it is working

• How the information gathered through REACH

is used will measure the Regulation’s success

• There is no alternative to REACH – stakeholders

are encouraged to roll up their sleeves and make

it more efficient

PanellistsModerator: Erwin Annys (Cefic)

Panel: Vito Buonsante (ClientEarth); Björn Hansen (DG Environment, European Commission); Andrea Paetz (Bayer);

Jake Sanderson (Environment Canada); Jan Wijmenga (Ministry of Infrastructure and Environment, the Netherlands).

ContextThe tenth anniversary of the entry into force of the EU REACH Regulation gives industry stakeholders the opportunity

to review its track record. Panellists and delegates discussed what this and other chemicals legislation has done to protect

human health and the environment, and if it has managed to protect competitiveness and support innovation at the

same time.

The debate

Panel Debate 2:

The sustainable development goals – is there a business case?

SDGs

Current status

• Chemicals safety permeates all 17 SDGs

• The SDGs can only be achieved if chemicals

are managed safely

• Much progress has been achieved on the way to the

Saicm 2020 goals, and the SDGs present a further

opportunity to develop a more comprehensive global

chemicals management framework post-2020

• Because chemistry runs through all SDGs, we need

a multi-sectoral approach to chemicals safety

The business case

• Industry will contribute to the SDG goals and

Saicm processes today and in the future

• Incentives are needed to encourage innovation

from industry

• SDGs present a large opportunity for innovative

SMEs to develop alternative chemicals, materials

and technologies

• To fulfil any of the 17 SDGs, emphasis should be put

on number five – achieve gender equality and empower

all women and girls. Women and chemicals safety play

an important role in achieving this

• Over the last two decades, the European chemicals

industry has lost worldwide market share, while

the global market has increased rapidly. Topical

sustainability issues, like the transition to a low

carbon economy or the promotion of adoption towards

circular economy principles, offer new opportunities.

In this respect, the SDGs give companies an additional

roadmap for innovating products to meet societal

challenges in future

Mood in the room – key take-home messages

• All SDGs rely, in some way, on the safe management

of chemicals

• Industry and the public need to be aware that the

SDGs represent opportunities as well as challenges

• Chemicals safety is an important piece of the

sustainability puzzle and every step of the challenge

must be considered, avoiding thinking in silos

• To achieve chemicals safety and the SDGs, stakeholders

must come together to develop innovative solutions

to the challenges we face

PanellistsModerator: Achim Halpaap (Chemicals and Waste Branch, Unep, Belgium)

Panel: Ricardo Barra (University of Concepción, Chile); Leticia Carvalho (Ministry of Environment, Brazil);

Qian Cheng (Greenpeace East Asia, China); Timo Unger (Hyundai Europe, Germany); Hartwig Wendt (Cefic).

ContextSafe chemicals management plays an important role in achieving several of the UN’s sustainable development goals

(SDGs), which were adopted in 2015 to guide societal and planetary needs up to 2030. Panellists discussed how

businesses should engage with them and explored the bottom-line risks of not doing so.

The debate

Panel Debate 3:

Post-2020 global chemicals supply chains – what will be the drivers for market supply and demand and will chemicals product safety emerge a winner or loser?

Supply chain challenges

• Sustainable products and energy demands will be

strong market drivers post-2020 – the latter are putting

great pressure on chemicals producers, as well as

article manufacturers

• As the manufacturing of nanomaterials increases,

chemicals safety will have to be addressed at the

nanoscale much faster than it is currently

• Consumers are becoming increasingly educated on

chemicals and are demanding safer, greener products

• Alignment of global frameworks is needed to help

businesses obtain the right information they need

• The circular economy will require a complete

transformation of business models

• Political, economic and social uncertainty are potential

barriers to transforming business models

• There are multiple sources of disruption affecting global

markets and business planning. This brings many

opportunities, but how can we facilitate innovation

and human progress?

Solutions

• Potential for supply chain synergies – downstream

users must work closer with chemicals producers

to develop substances that suit specific applications

• Technology, such as artificial intelligence and ‘big data’,

are potential solutions to many supply chain issues

• Regulatory harmonisation is needed in this climate

of uncertainty – setting common standards and the

reliability of chemicals are vital

• To know all chemicals in products, information

from all stages of the supply chain is required

• Personnel at manufacturing sites need to be

educated on how to obtain information on chemicals

from producers

• Restricted substances lists (RSLs) and manufacturing

restricted substances lists (MRSLs) are being used

as communication tools by downstream users

• The UN’s Chemicals in Products programme has

the potential to be an effective and useful initiative

for downstream users of chemicals

• SDGs can keep supply chains and business models

focused on the goals set

• Green chemistry has the potential to grow rapidly

and outpace conventional chemicals manufacturing

• A safer chemicals strategy for industry is crucial –

this would establish how we find and develop safer

chemicals and implement them

Mood in the room – key take-home messages

• Information is a key driver for safety

• The EU market will only become smaller

on the global stage

• Supply chains will become more complex,

along with products and the chemicals used

• The public will demand safer chemicals and industries

closest to the consumers will find it easier to change

their business models

PanellistsModerator: Bjørn Hansen (European Commission)

Panel: Rafael Cayuela (Dow, US); Joseph DiGangi (Ipen, US); Anouschka Jansen (Foreign Trade Association, Belgium);

Mihai Scumpieru (Mitsubishi Electric Europe and Japan Business Council in Europe); Peter Smith (Cefic).

Context Taking into account macro-economic forecasts, global market trends and supply chain needs, the panel debated what the

products of tomorrow will look like and discussed the implications for the drive to achieve safer chemicals in products.

The debate

Panel Debate 4:

Speeding up chemicals assessments – from novel information to new management approaches – what works?

Chemical assessments

Current status

• For OECD countries the mutual acceptance of data

(MAD) system is important. MAD has to evolve to

accept novel approaches to testing

• Gaining access to in vivo data is critical for regulators

to assess its value

• Development of adverse outcome pathways

and building of chemical pathways is slow

• Regulators and industry want methods that are relevant,

reproducible, broadly available, recognised as usable

for defined regulatory purposes and well characterised

• There is a fragmented global picture when it comes

to acceptance of alternative assessment by regulators

• REACH is geared towards assessing one substance

at a time, which results in slow progress in controlling

chemicals risks

• Consideration should be given to a grouping approach

to achieve faster results and reduce animal testing

• Future discussion should look at moving REACH from

being a chemicals-based regulation to a use-based one

• Companies are making use of existing data in screening

chemicals during R&D; regulators could learn from

their methodology

• Hazards of chemicals are international –

irrespective of the country in which they are used

• International hazard data should be used for local

risk assessment

• Obstacles to data sharing are more political

than technical

• People are increasingly accepting in silico and

in vitro methods for regulation requirements

• There are philosophical and social challenges to

new approaches but also to traditional in vivo testing.

We need a transparent discussion of these

• Acceptance of new approaches does not necessarily

speed up regulatory approval processes as regulators

need to check assumptions more carefully

Solutions

• Novel approaches should not be systematically

opposed in favour of traditional ones

• Stakeholders must build a strategy of how

novel approaches can fit together

• Collaboration between OECD countries is important

but it must also take place with countries outside

the OECD, such as China

• People can reach different conclusions but it must

be clear why these are reached

Mood in the room – key take-home messages

• Moving together is more important than moving faster

• There is ‘no one size fits all’ approach to chemicals

assessment

• Data should be shared and people must be transparent

about the data that decisions are based on

PanellistsModerator: Mamta Patel (Chemical Watch)

Panel: Dorte Bjerregaard Lerche (Ministry of Environment and Food, Denmark); Anne Gourmelon (OECD);

Erika Kunz (Clariant); Brian Richards (Office of Chemical Safety, Australia); Russell Thomas (US EPA).

ContextStakeholders in various countries are trying different approaches to avoid animal testing. The aim is to speed up chemicals

assessment and management including grouping, fast-tracking restrictions and computational screening. But how does

this all work in practice and what are the trade-offs for society in using these approaches?

The debate

Panel Debate 5:

Substances of concern (SVHCs) in products – whose job is it to control these in a free trade world?

Key issues

• There is a lack of knowledge about the presence

and fate of hazardous substances in articles

• Analysing all chemicals in products on the EU market

is not a viable solution as millions of products are

imported. It would be too costly

• Legislation is a baseline expectation but retailers

must have their own initiatives, such as chemicals

management programmes – which include monitoring

of suppliers – to identify sustainable practices

• Performance demands and design criteria for

certain consumer products pose real challenges.

Sometimes safer alternatives do not offer similar

performance attributes

• Transparency and communication are difficult

in complex supply chains, the actors in which

can often change

• Industry has a key role in controlling SVHCs in articles

but everybody in the value chain – governments,

manufacturers, suppliers, retailers and consumers –

has a responsibility

• Lack of comprehensive legislation in emerging

economies, such as India, is problematic for chemicals

control and consumers are less aware of the hazards

in these regions

• Substances in articles will play a prominent role

in the EU’s strategy for a non-toxic environment

• MRSLs and RSLs play an important part in combating

the problem

• Confidential business information (CBI) and intellectual

property (IP) rights can prevent open dialogue

Recommendations

• The issue can only be tackled by a combined

effort from all players in the value chain

• Action is needed nationally as well as internationally –

players should strive for harmonisation

• More transparency and better communication

will improve the handling of SVHCs in articles

• Greater consumer awareness is needed, especially

in emerging economies

• Authorities must address the interface between

waste legislation and the circular economy

• SVHCs should be tracked in order to achieve

a successful circular economy

• Third parties can potentially play a role in overcoming

issues of CBI and IP and help bring assurance and trust

Mood in the room – key take-home messages

• International collaboration is essential and everyone

in the value chain bears responsibility

• Control of SVHCs in articles is a vital consideration

in non-toxic environment strategies

• Consumer awareness of such substances must

be improved

PanellistsModerator: Jack de Bruijn (Echa)

Panel: Ravi Agarwal (Toxics Link, India); Karin Kilian (European Commission); Remi Lefevre (Echa);

Kevin Mulvaney (American Chemistry Council); Matthias Schmid (Adidas).

ContextUnregulated EU imports of articles, which expose people and the environment to dangerous chemicals,

continue to frustrate regulators and industry. An international cross-body panel discussed the magnitude

of the challenge and what regulators and businesses can do to level the playing field.

The debate

» What about enforcement?

It remains the weakest link

of a successful chemicals

management system... lack of

harmonized rules in and outside

EU discourages pro activity

of industry... when will we have

a global commitment from the

competent authorities directly

(not at the political level)?

» Indeed enforcement by the

member states is not really

discussed even by the Dutch

representative although we

all know that it is a major flaw.

Could Bjorn and Jan explain

what will be done?

» EEB said at ECHA's 10th

anniversary day yesterday that

there seems to be little difference

in consequences for companies

that comply by providing adequate

data to demonstrate good control

of risk vs. those that do not.

Both get a registration number.

How can this be addressed

in the next ten years?

» #integrated and #sustainable

#chemicals and #product

policies are #prerequisites

for #circulareconomy

#ChemicalsForum @yministerio

https://t.co/ZLwVOtBhyc

» The USA and Canada go for a

risk-based approach, whereby

the EU is following a hazard-based

approach "hunting" for SVHCs.

Can you clarify which approach (1)

serves the goals more effectively

and (2) is economically (time and

cost) more efficient?

» What has legislation done for us?

- can the panel discuss the impact

of modernised regulation on

innovation and substitution

of hazardous chemicals?

» What has legislation done for us?

- can the panelists each say what

would be their key performance

indicator of success (or failure)

of chemicals management in

the next 10 years?

» 10 years has passed and more

than 80% of chemical industry

produce hazardous products.

No on the ground actions

been implemented more

than documentation!

» Jan Wijmenga, Dutch environment

ministry: REACH a success, but

needs improving, e.g. need to

assess combination exposure

#ChemicalsForum

» For B.H.: are sustainable/ green

chemistry going to be really

effective for circular economy

of chemicals?

» Echa's Geert Dancet reiterates

‘consumers not getting enough

information on chemicals in

products’ #ChemicalsForum

» Andrea Paetz of Bayer says

REACH not perfect but knowledge

and regulation of chemicals is

much better #ChemicalsForum

» Knowing what we know now with

10 years of experience, would

REACH or its implementation look

any different if today was Day 1?

Panel 1: What has chemicals legislation done for us?

Panel 2: The sustainable development goals – is there a business case?

» Regarding substitution, innovation,

circular economy, etc.: Could the

panel discuss how OEMs shall

address these issues. Planning

horizon and product life cycle

for e. g. TV industry may be 5 - 10

years, for the automotive industry

probably 20 - 30+ years. What

do you suggest these industries

should do when planning new

products NOW in order not to

be confronted with future SVHCs

in their products?

» Ricardo Barra of Chile's University

on Conception says innovation

to tackle pollution eg. plastic waste

at source rather than at the end

of product life is critical especially

with the growth in middle class

consumer markets globally.

How to create the right economic

incentives to drive businesses

in this direction?

» The SDGs are forging connections

'at organisational level' between

health, housing and environment

policy-makers in Brazil in pursuit of

sustainability eg. to end use

of lead paints. Is this happening

in other public and private sector

organisations too?

» Greenpeace China: companies

manufacture without regard for

chemicals contamination of local

public sites and little enforcement.

What will it take to build the

impacts on health, environment,

food, water into the business

case for regulatory and business

activity?

The Writing on the WallAn unedited selection of comments posted to the message wall by the audience

» Most of the sound management

of chemicals programs/ plans

are under the SDG12 (SCP).

Considering the importance

of pesticide/ chemicals/ biocides

isn’t it better to define another

separate SDG (eg., no 18)

for chemicals pollution?

» This morning the picture was

painted that REACH had not

impacted on the chemical

industry in Europe. Yet the CEFIC

presentation said that we had

consistently lost share from 32%

to 17%. Does this not mean that

we have effectively just exported

all our hazardous chemicals and

then purchase the finished articles

leaving the problem in the third

world. So has it really been such

a success?

» Ricardo Barra: "Plastics is for

chemicals what carbon is for

climate change" #ChemicalsForum

good analogy on the problem

with plastics

» European chemical industry may

have lost some of its global market

share but the overall market has

expanded massively. Instead of

lamenting the pollution elsewhere,

isn't this an opportunity for

European industry to compete

on sustainability standards of

products? REACH is raising the

product stewardship bar in Europe

and those who want to export

to the world's largest economic

bloc need to pay to play.

» For sustainability to truly flourish,

in addition to a real global

knowledge sharing (both data and

regulations), regulations should

also be based on sustainability

pillars. Hazard alone triggers

regrettable substitution decisions

hampering sustainability overall.

The current classification system

does not allow distinguishing

substances from a potency

viewpoint. All CMRs are grouped

and stigmatized no matter

the inter-substance variability

of the potency and severity of

effects, or their environmental

production and consumption

footprint. Sustainability needs

a refined classification system

to consider more than just hazard

and grow closer to a functional

risk assessment.

» Looking further ahead after

2020 in terms of global chemical

management as well as in line

with the underpinning principles

in Responsible Care; how does

industry justify the continuation

of manufacturing hazardous

chemicals, banned from use

in e.g. the EU, only to export to

developing countries? Are global

bans of chemicals a necessity

beyond 2020?

Panel 3: Post-2020 global chemicals supply chains

» To Mihai Scumpieru: Is there scope

to develop ChemSherpa as a

global chemicals declaration tool?

» Circular economy ==> rethink of

product functionality and business

models ==> increasing complexity

of supply chain communication

but also driver of up- and

downstream collaboration?

» To Rafael Cayuela: in the race to

'singularity' where sustainability,

digital and citizen revolutions

come together, which types of

companies will be the winners

and losers?

» When hazard reduction has

been implemented and risk

management yields proper

protection of human health and

environment, little recognition is

given and pressure/stigmatization

continues. Keeping pressure is

healthy but stigmatization and

misinformation are counter-

productive. Many hazardous

substances are key to society and

can be used safely from cradle

to grave. If more information of

presence and impact of hazardous

substances is what public wants,

let’s define a fit-for-purpose

communication tool, somewhere

between current labels and

product information sheets,

destined to reassure citizens.

» Joe DiGangi from @ToxicsFree

shows the real cost of

chemicals and the harm from

using hazardous chemicals.

#ChemicalsForum inspiring!

» Accuracy of hazard based

assessment is about the

same as that of tossing a coin.

Lots of wrong positives and

wrong negatives.

» The market supply and demand

will not survive on the basis of

non-hazardous chemicals only!

Risk assessment is the key to

inform sustainable and realistic

market supply and demand.

Panel 4: Speeding up chemicals assessments

» Many countries are reluctant to

accept read-across but wouldn’t

this avoid duplication and

encourage data-sharing globally?

Why are these countries saying

no to read-across?

» Erika Kunz. @clariant nos explica

las ventajas de la herramienta

AMBIT de @Cefic LRI

en #chemicalsforum

https://t.co/H7nrtTNKSa

#pruebalo

» A new substance is added to the

CAS register every second. If it

takes years to globally regulate

a single substance, Minamata

Convention for example - what’s

our best hope for tackling the

increasing number of substances

entering the market that potentially

increase the toxicity of our society?

Seems we are trying to reach

the top of a mountain that never

stops rising.

» Our Danish panelist makes an

interesting point - shouldn’t we be

assessing substances on a use or

product basis? Something which

the European Commission seems

to be considering.

» With all we hear on the variability

of results in in vivo data and on

how little animal data can predict

with certainty human reality (and

inform human safety thereby),

why do we continue to push so

much for animal testing rather

than investing more actively

in human population health

surveillance and monitoring?

Stop extrapolating with excessive

assessment factors on a very

conservative basis when the

animal models we start from seem

to be not representative or over

sensitive already! At the pace we

go any and all substance will end

up being classified and banned

with no true added value for

human safety…

» Health surveillance can be done

in a tailored manner taking due

consideration of all relevant

parameters and using the latest

statistical analytical approaches...

it would not be more complicated

(and less fit for purpose) than

what we currently are doing

when “extrapoguessing” political

decisions based on models and

data known to be unfit to predict

human safety…

Panel 5: SVHCs in products

» To Matthias Schmid of ADIDAS:

Extending chemical risk

management from supply tier one

back to tiers 2,3,4 must become

less and less accurate - how

confident are you that you know

what is going on?

» India is the largest producer of

DDT (DDT use is coming back

again for malaria..etc.) and on

the other hand India itself is the

biggest victim of the chemical

industry.

» To Ravi Agarwal: Can you foresee

a tipping point to drive mainstream

consumer awareness of product

safety, regulation and industry

proaction in India? What will

it take?

» Hazardous chemicals in products

@EU_ECHA explains how industry

is not complying with REACH

- refusing to take responsibility

#chemicalsforum

» Supply chain and consumer

communication and information

is a two-way process. Lack or

differences in awareness and

knowledge at each end of the

chain can only be tackled by

a common notification system

and a proper enforcement.

» As a manufacturer I am

constantly bombarded with

compliance requests - RoHS,

REACH compliance, Palm

Oil, SVHC, FDA food contact,

Drinking Water ...... this takes

considerable time to understand,

assess and reply….I wonder if

my competitors outside Europe

just send the signed statement

back to the customer without

even reading or understanding

it or offer 5% discount to get the

business. Regulation with strong

enforcement of suppliers outside

Europe is VITAL.

» How to address the thin line

between IPR and “must have

information” in notification

obligations?

» @Malik_CoE @EU_ECHA

Responsibility means knowing

what is in your product and

being transparent about it.

And complying with the law

#chemicalsforum

» Companies are populated by

citizens who like to think that

they know what a typical citizen

would want to know on the articles

they use. This guides part of

the communication standards

they develop. More partnerships

across industry sectors and with

authorities and NGOs could

deliver a more holistic view of what

citizens need to know. If there is no

agreement on what citizens need

to know, no notification system

can be built.

» How is release (leaching and

migration) of a substance from

an article taken into account in

REACH processes or is it only

the presence of the substance

in an article that matters? Is there

a need for a notification of SVHC

substance to ECHA if exposure

to a substance in an article can

be excluded?