Comments on ECHA’s Draft 9th Recommendation for Reaction products of 1,3,4-thiadiazolidine-2,5-dithione, formaldehyde and 4-heptyl-phenol, branched and linear (RP-HP) [with ≥0.1% w/w 4-heptylphenol, branched and linear]  (EC number: -) and references to responses

The present document compiles the comments received during the public consultation on the draft 9th recommendation for inclusion of substances in Annex XIV of REACH for Reaction products of 1,3,4-thiadiazolidine-2,5-dithione, formaldehyde and 4-heptyl-phenol, branched and linear (RP-HP) [with ≥0.1% w/w 4-heptylphenol, branched and linear1]  (EC number: -). The public consultation took place between 5 September 2018 and 5 December 2018.

For each of the comments there is also a reference to specific section(s) of a document containing the responses to comments (“Response document”, available at https://echa.europa.eu/documents/10162/13640/9th_recom_respdoc_rp-hp_en.pdf). The responses in the Response document are arranged by thematic block and level of information (see more detailed explanations at the beginning of that document).

PUBLIC VERSION

Content
	
I - General comments on the recommendation to include the substance in Annex XIV
II - Transitional arrangements. Comments on the proposed dates
III - Comments on uses that should be exempted from authorisation, including reasons for that

I - General comments on the recommendation to include the substance in Annex XIV
Number / Date	Submitted by (name, submitter type, country)	Comment	Reference to responses	
3333
2018/12/05	ChemSec,
International NGO,
Sweden	ChemSec supports the prioritisation of 1,3,4- thiadiazolidine-2,5-dithione, formaldehyde and 4-heptylphenol, branched and linear [with ≥0.1% w/w 4- heptylphenol, branched and linear ] (RP-HP)
for inclusion in Annex XIV.
	Thank you for your opinion.	
				
3355
2018/12/05	Norway,
Member State	The Norwegian CA supports the prioritisation of Reaction products of 1,3,4-thiadiazolidine-2,5-dithione, formaldehyde and 4-heptylphenol, branched and linear (RP-HP) with ≥0.1% w/w 4-heptylphenol, branched and linear (4-HPbl) for inclusion in Annex XIV. The reaction product is identified as a SVHC and included in the Candidate list according to Article 57 (f). This is based on scientific evidence of endocrine disrupting properties of probable serious effects to the environment which give rise to an equivalent level of concern as those of other substances listed in points (a) to (e) of Article 57 of REACH. Furthermore, the use is wide dispersive with a high tonnage. We consider the prioritisation criteria to be fulfilled.	Thank you for your opinion.	
				
3385
2018/12/05	CHEM Trust,
National NGO,
United Kingdom	CHEM Trust strongly supports the prioritisation of 1,3,4- thiadiazolidine-2,5-dithione, formaldehyde and 4-heptylphenol, branched and linear [with ≥0.1% w/w 4- heptylphenol, branched and linear ] (RP-HP) for inclusion in Annex XIV.	Thank you for your opinion.	

II - Transitional arrangements. Comments on the proposed dates
Number / Date	Submitted by (name, submitter type, country)	Comment	Reference to responses	
3355
2018/12/05	Norway,
Member State	In general, we are in favour of a short LAD slot.	B.1.1.3. ECHA's proposal for latest application dates

Thank you for your opinion.

III - Comments on uses that should be exempted from authorisation, including reasons for that
No comments received.