Breaking! EU Identifies DBDPE as a Substance of Very High Concern, SVHC List to Expand to at Least 251 Entries

On October 9, 2025, the European Chemicals Agency (ECHA) announced that the Member State Committee (MSC) unanimously agreed during its October meeting to classify 1,1’-(1,2-ethanediyl)bis[pentabromobenzene] (Decabromodiphenyl Ethane, DBDPE) as a Substance of Very High Concern (SVHC). ECHA plans to officially publish the notice in November 2025, adding it to the SVHC Candidate List. This move will further advance the phase-out of brominated flame retardants.

In addition to the obligations under REACH regulations after listing, identifying DBDPE as an SVHC will also help promote potentially feasible restrictions on brominated flame retardants. This action aligns with the deadline for transferring the substance to the harmonized classification and labeling list under the CLP Regulation.

Proposed New SVHC Substance Information:

Substance Name

CAS No./EC No.

Proposed Reason

Common Uses

1,1'-(ethane-1,2-diyl)bis[pentabromobenzene]

(DBDPE)

CAS No. 84852-53-9

EC No. 284-366-9

vPvB (Article 57e), very persistent and very bioaccumulative

vPvB (Article 57e)

Primarily used as a replacement for decabromodiphenyl ether flame retardants, commonly found in HIPS, ABS resins, and plastics such as PVC and PP. Widely used in the following products: adhesives and sealants, coating products, fillers, putty, plaster, modeling clay, inks and toners, leather treatment products, lubricants and greases, polishes and waxes, polymers, washing and cleaning products, and cosmetics and personal care products.

Additionally, the EU recently withdrew one proposed SVHC substance: dodecamethylpentasiloxane (CAS No. 141-63-9, EC No. 205-492-2). This substance was initially proposed for the SVHC Candidate List due to its potential very persistent and very bioaccumulative (vPvB, Article 57e) properties. However, after further scientific evaluation and stakeholder feedback, ECHA decided to withdraw the proposal.

As of now, the summary of SVHC-related information is as follows:

The SVHC Candidate List consists of 33 batches totaling 250 substances.
1 substance proposed for addition (Decabromodiphenyl ethane).
1 substance under consideration (Resorcinol).
3 substances under SVHC public consultation.
No SVHC intention substances (public consultation not yet initiated).

The Current 3 Substances under SVHC Public Consultation:

Substance Name	CAS No./EC No.	Proposed Reason	Common Uses
N-Hexane	CAS No.: 110-54-3EC EC No.: 203-777-6	Substances of equivalent concern having probable serious effects to human health (Article 57f - human health).	Used in polishes and waxes, adhesives and sealants, antifreeze, biocides, coating products, fillers, putties, plasters, modelling clay, finger paints, non-metal-surface treatment products, inks and toners, leather treatment products, lubricants and greases, perfumes and fragrances, textile treatment products, dyes, cosmetics and personal care products.
4,4'-methylenediphenol (BPF)	CAS No.: 620-92-8 EC No.: 210-658-2	Reproductive toxicity (Article 57c). Toxic for reproduction (Article 57c)	Primarily used in the production of epoxy resins, polycarbonate resins, and polyester resins, as well as in the manufacture of textile dyeing auxiliaries, thermal-sensitive materials, flame retardants, antioxidants, and surfactants.
4,4'-[2,2,2-trifluoro-1-(trifluoromethyl)ethylidene]diphenol (BPAF) and its salts	/	Reproductive toxicity (Article 57c). Toxic for reproduction (Article 57c)	Mainly used as a monomer for synthesizing fluorine-containing polymers, and also for producing dyes, photosensitive materials, and optical brighteners.

CIRS Insights

For products exported to Europe containing SVHCs above 0.1%, companies must fulfill information transmission and SCIP notification obligations. If the export volume of SVHCs exceeds 1 ton/year, SVHC notification is also required.

Corporate Responsibilities and Obligations

Companies should note that products containing SVHC substances entail corresponding responsibilities and obligations:

Provide a Safety Data Sheet (SDS) to downstream users when SVHCs are sold individually.
If SVHCs are components in a mixture and the concentration is ≥0.1%, an SDS must be provided.
If SVHCs constitute >0.1% by weight in an article, detailed information must be provided to downstream users or consumers within 45 days for free.
If a single SVHC constitutes >0.1% by weight in an article and the annual export volume exceeds 1 ton, the manufacturer or importer must notify ECHA within six months.
From January 5, 2021, products containing >0.1% SVHC must be reported under the SCIP directive, in accordance with the EU Waste Framework Directive (WFD).

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