Substances of Very High Concern in the Netherlands (ZZS): your obligations

Substances of Very High Concern (Zeer Zorgwekkende Stoffen, ZZS) are regulated especially strictly in the Netherlands because of their serious effects on people and the environment. Think of carcinogenic, mutagenic, reprotoxic, persistent or bioaccumulative properties. The government aims to keep these substances out of the living environment as much as possible.

ZZS, SVHC and SZW: how do they relate?

The terms overlap but are not identical:

• SVHC is the European REACH Candidate List of substances of very high concern.
• ZZS is a broader Dutch policy list; many SVHC substances are also ZZS, but the ZZS system draws on more sources and criteria.
• The SZW list of carcinogenic, mutagenic and reprotoxic substances is a separate, legally anchored list under the Working Conditions Decree.

A substance can therefore appear on several lists at once, each with its own obligations.

What obligations apply?

Minimisation. For ZZS there is a duty of effort to prevent and limit emissions to air and water as far as possible.

Avoid and substitute. You must periodically examine whether a ZZS can be replaced by a less harmful alternative or a less harmful technique.

Five-yearly review. Companies with an environmental permit must typically demonstrate every five years what steps they have taken to avoid or reduce ZZS.

Information in the supply chain. If a ZZS is also on the SVHC Candidate List, the REACH duties to pass information to customers apply. For other ZZS it is good practice, so customers can meet their own obligations.

What should you do in practice?

1. Screen your inventory. Check every component in your products — by CAS number — against the current ZZS list. Product names are unreliable; the same substance appears under many trade names.

2. Document the presence. Record in which products and at which workplaces a ZZS is present, and at what concentration.

3. Substantiate your substitution review. Even where substitution is not (yet) possible, you must be able to show that you made the assessment.

4. Keep it current. The list changes. A one-off screening is not enough — every time it expands, existing products must be re-checked.

How Chemspark helps

Chemspark screens your whole register automatically against the ZZS list, the SVHC Candidate List, the SZW list and the REACH lists (Annex XIV and XVII), based on the CAS numbers of the individual components. It recognises CMR substances by their H-statements and by components on the SZW list. When Chemspark updates a list, you get a notification if one of your products contains a newly listed substance. So you don't have to work through the lists yourself.