What to Do When a Substance Appears on the Authorisation List

Landing on the Candidate List means a communication duty. Landing on the Authorisation List is a different order of problem: it means a specific use of that substance can’t legally continue past a set date, called the sunset date, unless someone in the supply chain holds a valid authorisation for it. If a substance you manufacture, import or use turns up on the Authorisation List, here’s the practical sequence to work through.

Step 1: Work out if it actually affects you

Authorisation applies to specific uses, not a substance in every context it might appear. The first job is establishing whether your role — manufacturer, importer, formulator, or downstream user — and your specific use of the substance falls within scope, or whether you’re several tiers removed and only affected indirectly through a component or material you buy in.

Step 2: Check whether an authorisation already covers you

You may not need to apply for anything yourself. If a supplier further up your chain already holds an authorisation that covers your specific use, your obligation may simply be to notify the relevant use and keep records — a much lighter task than an application. This is where accurate supply chain communication earns its keep: you can’t rely on an authorisation you don’t know exists.

Step 3: If nothing covers you, choose a path

If no authorisation in your chain covers your use, there are really three options:

• Substitute — replace the substance with an alternative before the sunset date. Often the lowest-risk option long-term, but it needs enough lead time to qualify, test and validate a replacement.
• Apply for authorisation — a substantial technical and economic exercise, requiring a case that the risk is adequately controlled or that the socio-economic benefits outweigh the risk, alongside an analysis of alternatives. This is not a quick form to fill in.
• Exit the use — stop the specific use before the sunset date if neither substitution nor an application is viable in time.

All three take time to execute properly, which is why the sunset date matters more than it might first appear — it’s not a distant deadline, it’s the point by which one of these three paths needs to already be resolved.

Step 4: Don’t treat it as a one-off decision

Authorisation decisions get reviewed, and conditions or time limits can change. A substance you cleared two or three years ago can see a fresh decision published that affects your specific use again — which is exactly why authorisation exposure needs to sit on a recurring review cycle, not a single tick-box exercise.

How we can help

We help clients work out quickly whether an Authorisation List entry actually affects their specific use, map where authorisation already exists in their supply chain, and build a realistic plan — substitution, application or exit — before the sunset date narrows the options.

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