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REACH with 254 SVHC

The European Chemicals Agency (ECHA) continues to tighten chemical safety across the EU by updating the Candidate List of Substances of Very High Concern (SVHCs) under REACH. The list keeps growing; now, as part of the latest consultation, ECHA proposes adding three substances—Bisphenol AF (and its salts), Bisphenol F, and n-hexane—based on significant human-health concerns (notably reproductive toxicity for the bisphenols and specific target organ toxicity for n-hexane). If adopted, the Candidate List would expand by three entries (REACH with 254 SVHC).

Let’s unpack the essentials behind these widely used chemicals—where they appear, why regulators scrutinize them, and how their potential SVHC classification could impact your obligations under REACH (Article 33 communication, Article 7(2) notification, and substitution planning).

REACH SVHC
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The three proposed SVHCs at a glance

1) Bisphenol AF (BPAF) and its salts

Why proposed: commonly flagged for reproductive toxicity concerns.
Where it can appear: For example, high-performance polymers, fluoroelastomers, specialty rubber processing, epoxy or resin systems as a monomer, cross-linker, or process regulator.
What to do: screen polymers, review elastomer specs, request updated declarations from seal, gasket, and coating suppliers.

2) Bisphenol F (BPF)

Why proposed: reproductive toxicity concerns similar to BPA.
Where it can appear: For example, BPA substitutes in adhesives, coatings, encapsulants, varnishes, liners, sealants, and composites.
What to do: trace where BPA alternatives entered your designs, confirm resin grades, and validate supplier substitutions with CAS/EC identifiers.

3) n-Hexane

Why proposed: specific target organ toxicity (repeated exposure), long-standing neurotoxicity concerns.
Where it can appear: For example, cleaning agents, coating thinners, degreasing steps, polishes, waxes, and certain process solvents.
What to do: map finishing and maintenance operations, replace where feasible, control exposure, and document low-residue specifications.

Substance Name

CAS #

Proposing Authority

Hazard & Concern

Application (Where they are used)

Ref.

Bisphenol AF (and its salts)

1478-61-1 (parent)

Member State dossier (under ECHA public consultation)

Repr. toxicity — proposed as toxic for reproduction (REACH Art. 57(c)). Frequently discussed for endocrine-disrupting potential.

  • High-performance polymers and fluoroelastomers (FKM/FPM)
  • Epoxy and specialty resins (monomer/cross-linker)
  • Adhesives, sealants, coatings
  • Process regulators in rubber/plastics;
  • Electronics uses in gaskets, seals, laminates, and chemical-resistant parts.

1






Bisphenol F (BPF)

620-92-8 (4,4′-BPF; mixture may include other isomers)

Member State dossier (under ECHA public consultation)

Repr. toxicity — proposed as toxic for reproduction (REACH Art. 57(c)). Structural analogue/substitute for BPA; similar hazard concerns.

  • Adhesives, encapsulants, coatings/varnishes, liners, sealants, composites
  • BPA-replacement grades in resins
  • Potential use in dental and pipe/coating applications
  • Electronics potting and conformal coatings.

2

n-Hexane

110-54-3

Member State dossier (under ECHA public consultation)

Specific Target Organ Toxicity (repeated exposure) with neurotoxicity; proposed via equivalent level of concern – human health (REACH Art. 57(f)).

  • Cleaning/degreasing solvents, coating thinners, adhesive and sealant processing, polishes/waxes, printing and maintenance steps
  • Traces in polymer/parts finishing for electronics and assemblies.

3

Download the Current SVHC List Here

Immediate compliance impacts - REACH with 254 SVHC

  • Electrical & Electronic Equipment:
    BPF/BPAF can appear in epoxy resins, conformal coatings, potting/encapsulation, adhesives, and laminates; BPAF also shows up in fluoroelastomer seals and gaskets (FKM/FPM). n-Hexane may be used to clean, degrease, or thin coatings and adhesives during assembly.

  • Automotive:
    BPF/BPAF support adhesives, sealants, coatings, and composite bonding; BPAF can be present in high-temperature elastomers for under-hood seals, O-rings, and hoses. n-Hexane is often used in adhesive processing, surface prep, and parts cleaning on production lines.

  • Building & Construction:
    BPF is found in floor/wall coatings, binders, sealants, and composites; BPAF may occur in chemical-resistant linings and specialty resin systems. n-Hexane can serve as a solvent in certain coatings, primers, and sealant applications.

  • Textiles & Upholstery:
    BPF-based resins may be used in back-coatings, lamination, and adhesive systems for technical fabrics and interiors. n-Hexane may be used in spot-cleaning, finishing, or adhesive handling steps. (BPAF use is more niche, typically tied to specialized laminates or elastomeric components.)

  • Aerospace & Defense:
    BPAF appears in high-performance elastomers and epoxy systems demanding heat/chemical resistance; BPF supports structural adhesives and coatings. n-Hexane may be used in maintenance, repair, and overhaul (MRO) as a degreasing or surface-prep solvent.

Takeaway: map BPF/BPAF in polymer and resin chemistries (adhesives, coatings, sealants, elastomers), and trace n-hexane in solvent-based cleaning, thinning, and processing. Prioritize these areas for screening, supplier declarations, and substitution planning.

Why Are BPAF, BPF, and n-Hexane Being Proposed as SVHCs?

First, unlike DBDPE (driven by vPvB concerns), these three are flagged mainly for human-health hazards. Moreover, their widespread uses heighten potential exposure. Consequently, regulators are prioritizing precautionary action.

  • Bisphenol AF (and its salts)
    Basis: Toxic for reproduction (REACH Article 57(c)).
    Why it matters: Notably, evidence of fertility/developmental effects prompts tighter controls.
    So what: Therefore, if listed, suppliers must communicate above-threshold presence and consider substitution.

  • Bisphenol F (BPF)
    Basis: Toxic for reproduction (REACH Article 57(c)).
    Why it matters: Similarly, as a BPA alternative in resins, adhesives, and coatings, BPF can mirror similar risks.
    So what: Accordingly, teams should trace BPF in epoxy systems, verify formulations, and prepare Article 33 messaging.

  • n-Hexane
    Basis: Equivalent level of concern – human health (REACH Article 57(f)) via STOT-RE (neurotoxicity).
    Why it matters: However, repeated exposure can damage the peripheral nervous system.
    So what: Thus, manufacturers should map solvent steps, minimize exposure, evaluate alternatives, and document controls.

Ultimately, while DBDPE centers on persistence and bioaccumulation, the new trio centers on reproductive toxicity (BPAF/BPF) and chronic neurotoxicity (n-hexane)—so prepare for Article 33 duties, assess Article 7(2) triggers, and prioritize substitution or exposure-reduction strategies.

How Are BPAF, BPF, and n-Hexane Processed and Released? - REACH with 254 SVHC

First, bisphenols BPAF and BPF are used in resin systems (as monomers, cross-linkers, or additives). However, even when networks cure, residual monomers, oligomers, and process aids can still migrate, abrade, or wash off. Conversely—and by contrast—n-hexane is a volatile solvent used to dissolve, thin, clean, or degrease, thus releases primarily evaporate to air unless captured. Moreover, process conditions, cure ratios, and handling practices consequently influence release rates. Therefore, controls must target both polymer residuals and solvent vapors.

Where Releases Occur - REACH with 254 SVHC

Next, consider where releases occur:

  • Manufacturing
    Specifically for BPAF/BPF, incomplete cure, off-ratio mixes, and warm processes can liberate residuals; sanding, cutting, and drilling can generate dust carrying low-MW species. Notably on adhesive/coating lines, overspray and rinses can carry residues to wastewater and wipes. For n-hexane, open trays, wipedowns, and transfers can emit fugitive VOCs; leaks and spent filters consequently become emission sources. Therefore, local exhaust and closed handling are essential.

  • Use phase
    Meanwhile, articles containing bisphenol-based matrices can shed trace residuals under heat, humidity, UV, and wear; maintenance cleanings can move residues to wipes and wash water. Additionally, service operations that apply n-hexane for spot cleaning can release vapors without adequate capture. Nevertheless, good enclosure and ventilation accordingly reduce worker and environmental exposure.

  • End-of-life
    Subsequently, dismantling and shredding of bonded, coated, or encapsulated parts can create dust and fines that transport residual bisphenols; mixed-plastic streams can spread contamination. Furthermore, solvent-bearing rags, canisters, and filters may off-gas n-hexane or leach if containers aren’t sealed. Accordingly, pre-dismantling high-risk parts and segregating solvent wastes are critical. Nonetheless, inadequate capture or treatment can still drive releases.

Particularly in electronics recycling and mixed-material recovery lines, moreover, abrasion and fragmentation can amplify emissions; by contrast, facilities with strong dust capture, VOC control, and water treatment show markedly lower losses.

Ultimately, enclose mix/coat steps, optimize cure to minimize residuals, capture dust at source, use closed-loop solvent systems with LEV and carbon/condensation recovery, seal/segregate wipes and filters, treat rinse waters, and pre-dismantle sensitive assemblies—therefore turning high-risk release points into managed, auditable controls.

Registered Uses Under REACH with 254 SVHC

1. Formulation or Repacking

Manufacturers and mixers blend, react, or dilute these substances to produce:

  • BPF/BPAF: epoxy and specialty resin systems (monomers/cross-linkers), adhesives, sealants, coatings/varnishes, encapsulants, and laminates.

  • n-Hexane: solvent and processing aid for adhesives/coatings, cleaners, and diluents.
    Compliance note: These activities trigger Candidate List duties (e.g., Article 33/7(2)) and may be considered for future Authorisation if later placed on Annex XIV.

2. Industrial Use

At industrial sites, operators manufacture, apply, and process materials containing:

  • First, electronics: BPF/BPAF in conformal coatings, potting, underfills, lamination; n-hexane for degreasing, surface prep, and thinning.

  • Second, automotive: BPF/BPAF in structural bonding, sealants, composites; BPAF in high-temperature elastomer seals; n-hexane in adhesive lines and maintenance cleaning.

  • Next, Construction: BPF/BPAF in floor/wall coatings, sealants, binders; n-hexane as coating/primer solvent.

  • Then, Wires, Cables, Composites: BPF/BPAF in varnishes, matrix resins, impregnation systems; limited n-hexane use in processing/cleanup.

  • At the end, other industrials: Textile laminations, polyester/epoxy dispersions, and chemical-resistant linings using BPF/BPAF; n-hexane in printing and parts cleaning.

3. Professional Use

Downstream professionals apply and handle products containing:

  • BPF/BPAF: adhesives, sealants, coatings, encapsulants used in installation, repair, or small-batch fabrication (electronics service, construction finishing, interiors).

  • n-Hexane: service/maintenance solvents for spot cleaning, degreasing, and surface prep; potential exposure without capture controls.

4. Consumer Use

Finished goods can contain cured systems where residuals may remain:

  • BPF/BPAF: present as part of bonded laminates, coated housings, appliance parts, technical textiles, and interior trims (residual levels depend on cure and formulation).

  • n-Hexane: typically not present as an active ingredient in consumer articles; trace residues may occur from processing but tend to dissipate—focus remains on professional/industrial handling.

5. Article Service Life

Articles enter the market and may release trace amounts over time or at end-of-life:

  • Electronic devices, automotive components, building materials, furniture, and interior assemblies that use BPF/BPAF-based adhesives/coatings or BPAF-containing elastomer seals can shed very low levels via wear, heat, or UV.

  • Maintenance operations that apply n-hexane (professional settings) can emit vapors; end-of-life dismantling/shredding can generate dust/fines from coatings/adhesives if controls are weak.

Action reminder: Map where BPF/BPAF resins and elastomers sit in your BOMs, identify n-hexane solvent steps, tighten capture/ventilation, optimize cure to lower residuals, and prepare Article 33 communications and—where applicable—Article 7(2) notifications.

What Should Companies Do? - REACH with 254 SVHC

Immediate Actions: Screen, Engage, and Prepare Article 33/7(2)

  • First, screen BOMs, materials, and processes for these substances—BPF/BPAF in resins, adhesives, sealants, coatings, and elastomers; n-hexane in cleaning, thinning, and degreasing—then map article-level locations and estimate % w/w. Next, engage suppliers for updated SDS and SVHC declarations naming CAS/EC identifiers, residual-monomer data (for bisphenols), and solvent-use statements (for n-hexane), and set clear deadlines. Additionally, prepare Article 33 customer notices and consumer-response templates, pre-draft safe-use advice, and align IFU/label text where relevant. Moreover, assess Article 7(2) triggers (SVHC > 0.1% w/w in articles and > 1 t/y where exposure cannot be excluded), compile tonnage estimates, and document exposure justifications.

Ongoing Controls: Substitute, Document, and Monitor for SVHC Compliance

  • Meanwhile, strengthen EHS controls for n-hexane: substitute safer solvents, install/verify LEV, use closed-loop cleaning, capture VOCs, and train staff.

  • Consequently, optimize resin cure to minimize residuals, enforce spec limits for BPAF/BPF, require CoCs, and audit high-risk suppliers. Therefore, update contracts/PO terms to mandate SVHC disclosure on change and embed checks at NPI/ECN gates. Thus, pre-qualify alternatives (materials/processes), pilot builds, and document fit/form/function plus risk, cost, and timeline impacts.

  • However, where immediate substitution isn’t feasible, justify continued use, minimize exposure, and plan a time-bound phase-down while maintaining downstream-user safety info. Ultimately, maintain a living register (e.g., SCIP entries and internal trackers), monitor monthly list updates, and retain records to demonstrate due diligence—acting early reduces legal risk, protects workers and customers, and positions your brand as a proactive steward of safer, compliant products.

Conclusion on REACH with 254 SVHC

Ultimately, treat BPAF, BPF, and n-hexane as “near-certain” SVHCs and move now. Therefore, map where they can occur, engage suppliers with targeted declarations, verify high-risk items, and prepare Article 33 customer notices and—if thresholds and tonnages apply—Article 7(2) notifications. Meanwhile, evaluate substitutions or exposure-minimizing designs so you can pivot quickly without derailing quality, cost, or timelines. Accordingly, embed these checks into NPI gates, automate follow-ups, and monitor monthly so updates never catch you off guard.

In short, act early, document clearly, and iterate. By doing so, you’ll protect your customers, stabilize your supply chain, and future-proof your REACH program. If you want a fast, practical boost—templates, supplier chasers, BOM screening, and a prioritized action plan—Enviropass can help you adapt, comply, and thrive.

Have more questions on SVHC Under REACH? Contact Enviropass for a free consultation!