The UK’s Health and Safety Executive (HSE) has published its 2025 draft recommendation to include new substances in Annex 14 (the Authorisation List) under UK REACH.
This forms part of HSE’s routine process to prioritise substances of very high concern (SVHCs) from the Candidate List.
Substances Proposed for Authorisation
Three substances are included in the draft recommendation, all classified as toxic for reproduction under Article 57(c) of UK REACH:
These chemicals are widely used in plastics, stabilisers, coatings, and lead-based additives, making this proposal significant for multiple industrial sectors.
Public Consultation — Open Until 4 February 2026
HSE has launched a public consultation seeking technical input from stakeholders.
Manufacturers, importers, downstream users, article suppliers, and OEMs are invited to provide:
• Data on current uses within Great Britain
• Exposure details and risk-management measures
• Socio-economic considerations
• Availability of safer alternatives
• Requests for exemptions or essential-use evaluations
Deadline: 23:59 (UK time), 4 February 2026.
Industries such as automotive, electronics, and plastics are particularly encouraged to participate.
Potential Implications for Industry
If the recommendation is accepted by UK authorities:
• Uses of these substances will require authorisation applications after designated “sunset dates.”
• Companies may face supply-chain disruptions if raw materials or components rely on these substances.
• Businesses may need to demonstrate safe use or shift to less hazardous substitutes.
• Non-compliance may trigger market restrictions, legal liabilities, or enforcement penalties.
Sectors relying on additives, stabilisers, lead compounds, and cooling system components may need immediate review and planning.
Reason for the Substances Prioritisation:
Under Article 58(3), substances are prioritised for Annex 14 if they are:
• PBT or vPvB,
• Used widely across industries, or
• Produced/imported in high volumes.
DOTE, TEL and related reaction masses meet SVHC criteria due to their reproductive toxicity and high-risk profiles.
Recommended Actions for Companies
• Review usage of DOTE, TEL, and related compounds in all materials and processes.
• Map the supply chain to identify imports, additives, stabilisers, coatings, and affected components.
• Evaluate alternatives and substitution strategies.
• Prepare data for the public consultation where relevant.
• Monitor post-consultation announcements on deadlines and compliance obligations.
Public Consultation Participation
Visit the HSE Consultation Portal and search for: “Draft recommendation (2025) for Annex 14.”
Submit views on:
• Transitional arrangements
• Essential-use exemptions
• Availability of alternatives
• Industry-specific impacts
Ensure that your submission is uploaded before 4 February 2026.
Reference: REACh Publication
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