This is more important for your compliance work right now than the PFAS firefighting-foam story we’ve been repeating: the UK REACH Candidate List consultation we flagged earlier this month closes at 23:59 on 20 August, and the window to act is closing with it.
A quick recap
HSE has six substances under consultation for addition to the UK REACH Candidate List: Medium-Chain Chlorinated Paraffins (MCCPs), O,O,O-triphenyl phosphorothioate (TPPT), OAPP, bis(4-chlorophenyl)sulphone (BCPS), bumetrizole, and perfluoroheptanoic acid (PFHpA) and its salts. TPPT is proposed on PBT grounds; OAPP and BCPS on vPvB grounds. PFHpA is another PFAS joining the UK Candidate List pipeline.
Why the deadline matters more than the list itself
If HSE receives no comments on a proposal, the substance is added to the Candidate List by default. Silence isn’t a neutral outcome here, it’s the path of least resistance to listing. Where comments are received, HSE has 45 days from the consultation closing to consider them and reach a decision. Either way, the clock that matters most right now is the 20 August deadline, not the eventual listing date.
What to do before the window closes
- If you haven’t already, search BOMs, SDSs and supplier declarations for these six substances and confirm CAS/EC identifiers with suppliers.
- Flag defence clients specifically. This is a much more immediate, actionable update than another general PFAS note, and it deserves to be treated that way.
- If any of these substances are material to your product range and you want to influence the outcome, a consultation response needs to be submitted before 23:59 on 20 August, not after.
- If you’re not submitting a response, at minimum get your documented starting position in place now, so you’re not starting from zero if any of these substances are listed.
Once any of these substances are added, articles containing them above 0.1% weight by weight potentially bring Article 33 communication duties into play from the listing date. That’s a short runway if the underlying screening work hasn’t already been done.
How we can help
We’re helping clients get their BOM and supplier declaration screening finished before the 20 August deadline, and preparing consultation responses where a client wants to make the case directly rather than accept the default outcome. Get in touch if you need this turned around quickly.
Want help applying this to your own product range?
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