1. Monitoring Overview
Monitoring date: September 1, 2026 (Tuesday)
Coverage: EU REACH SVHC Candidate List; US EPA TSCA Significant New Use Rules (SNUR)
Conclusion: Material policy changes are in force. ECHA added two new Substances of Very High Concern (SVHC-253), and the Article 7(2) notification deadline (2026-08-04) has now passed. The US EPA published a new SNUR final rule on 2026-08-26, effective 2026-10-26. Exporters should immediately screen supply chains and remediate compliance gaps.
2. EU REACH SVHC Candidate List (Key Change)
Effective date: Announced by ECHA on 2026-02-04
Baseline: The SVHC Candidate List increased from 251 to 253 entries (36th update).
| # | Substance | CAS No. | Reason for inclusion | Typical uses |
|---|---|---|---|---|
| 252 | 4,4′-[2,2,2-trifluoro-1-(trifluoromethyl)ethylidene]diphenol and its salts (Bisphenol AF / BPAF) | — (substance group, 9 substances) | Toxic for reproduction (Article 57c) | Cross-linking agent for fluoroelastomers, high-performance elastomers, specialty coatings |
| 253 | n-Hexane | 110-54-3 | Specific target organ toxicity after repeated exposure (Article 57f; neurotoxicity – first SVHC identified on an equivalent level of concern) | Formulation, polymer processing, coatings, cleaning agents |
Critical compliance milestone (PASSED): For articles containing these substances at ≥0.1% (w/w), the Article 7(2) notification to ECHA was due within six months of listing – i.e., by 2026-08-04. As of this monitoring date, that deadline has passed; companies that have not notified are now non-compliant.
Ongoing obligations:
- Supply-chain communication (Article 33): Articles with SVHC ≥0.1% require safe-use information to customers/consumers; consumer requests must be answered free of charge within 45 days.
- SCIP database notification: Under the Waste Framework Directive, articles with SVHC ≥0.1% must be reported to ECHA’s SCIP database.
- Authorisation risk: SVHCs may later move to Annex XIV; use would then require authorisation.
3. US EPA TSCA Significant New Use Rules (SNUR)
Latest actions:
- 2026-08-26: EPA published a SNUR final rule (24-5.5e) in the Federal Register, effective 2026-10-26. For chemicals previously subject to PMNs and TSCA 5(e) Orders, any “significant new use” deviating from the Order’s restrictions requires notification to EPA at least 90 days in advance.
- 2026-07-30: EPA proposed SNURs for 14 chemical substances (industrial catalysts, domestic fragrances, electronic materials, few-layer graphene nanomaterials, lithography/semiconductor compounds, etc.); public comment period ongoing.
- Other ongoing activity: Compliance dates extended for perchloroethylene (PCE) and carbon tetrachloride (CTC) risk-management rules (final rule 2026-07-23); TSCA 8(d) health & safety data reporting deadline extended to 2027-05-21.
4. Risk Level Summary
| Policy area | Risk level | Affected parties | Trigger |
|---|---|---|---|
| EU REACH SVHC (BPAF / n-Hexane) | Medium-High | Exporters of fluoroelastomers, elastomers, cleaners, coatings, electronic components to the EU | In force (2026-02-04); notification deadline 2026-08-04 passed |
| US TSCA SNUR (24-5.5e / 14-substance proposal) | Medium | Exporters of new materials, nanomaterials, electronic/semiconductor materials to the US | Effective 2026-10-26 / proposal under comment |
5. Recommended Actions (for Chinese Exporters)
- Verify immediately (within 7 days): Screen EU-bound articles for BPAF and n-Hexane; determine whether content reaches ≥0.1% (w/w).
- Remediate filings: If the 2026-08-04 Article 7(2) deadline was missed, notify ECHA now, keep records, and assess regulatory exposure.
- SCIP submission: For articles with these SVHCs ≥0.1%, prepare and submit information to the SCIP database.
- US-side readiness: Map US-bound products against SNUR 24-5.5e and the 14 proposed substances; reserve at least 90 days before any new use/import to file with EPA.
- Build a routine mechanism: Incorporate SVHC (updated every 6 months) and TSCA SNUR updates into your product compliance list; require Full Material Declarations (FMD) from suppliers rather than CoCs alone.
6. Sources
- ECHA official announcement (2026-02-04, 36th SVHC update)
- U.S. EPA / Federal Register: SNUR final rules (2026-08-26, 24-5.5e; 2026-05-22, 25-1.5e), proposed 14-substance SNUR (2026-07-30)
- WTO/FTA Consultation Network (MOFCOM): US EPA proposes SNURs for 14 chemical substances
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