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December 2013

SCP Regulations: DTSC’s Informational Candidate Chemicals List May Not Be As Informational As You Think….

Effective October 1, 2013, the Safer Consumer Products Regulations establish a complex process by which “responsible entities” (manufacturers, importers, retailers and assemblers) will be required to analyze chemicals of concern in specified consumer products — which DTSC will call “Priority Products” — to determine whether safer alternatives exist.  The outcome of these alternatives analyses will determine what regulatory response DTSC will impose on the Priority Product or the selected safer alternative; regulatory responses range from product information requirements (think Proposition 65 Plus) to end-of-life management requirements, to sales bans.  And, if this process weren’t complex enough, watch out:  DTSC’s “Informational” Candidate Chemicals List, which it released on September 26, 2013, may not necessarily reflect the actual universe of chemicals that may be deemed chemicals of concern under the new program. DTSC’s Candidate Chemicals List represents the critical first step in the new program’s cascade of key operative elements.  Only Candidate …Read More