Medium-chain chlorinated paraffins (MCCP) are in a cable sheath we put in electronic products sold in the EU. Are MCCPs on the REACH Candidate List, restricted under REACH Annex XVII or the EU POPs Regulation, and what are our Article 33 and SCIP duties?
Short answer: Yes, MCCP is on the REACH Candidate List. It is not in REACH Annex XVII. Its EU POPs Regulation listing is being implemented but is not yet confirmed in force. Because it is on the Candidate List, your cable sheath already triggers Article 33 communication and a SCIP notification wherever MCCP is present above 0.1% w/w.
Approach: I checked the ECHA Candidate List and its inclusion decision, REACH Annex XVII and the restriction registry, ECHA's list of substances under the EU POPs Regulation, the Stockholm Convention POPs list, and the consolidated texts of REACH and the Waste Framework Directive. For the POPs status I also checked EUR-Lex. I found no official confirmation that the MCCP act has been published in the Official Journal.
1. Candidate List: yes, since 8 July 2021
- The group entry "Medium-chain chlorinated paraffins (MCCP)" was added on 08-Jul-2021 as both PBT (Art. 57(d)) and vPvB (Art. 57(e)) [1]. It was added by ECHA decision D(2021)4569-DC [2].
- The group covers these members:
- The SVHC identification defines MCCP as UVCB substances with at least 80% linear chloroalkanes of C14 to C17 chain length [7].
2. REACH Annex XVII: no entry yet, but a restriction dossier exists
- I found no Annex XVII entry for MCCP or CAS 85535-85-9 in ECHA's restrictions list or in the consolidated REACH text.
- ECHA has prepared an Annex XV restriction proposal on "Chloroalkanes C14-17". It names PVC cables as the main use, including cables in electrical and electronic applications [8]. All the substance-in-article notifications ECHA received related to electrical cables [9].
- A search snippet from ECHA's registry of restriction intentions shows the case at "opinions adopted". I found no Commission decision on it.
3. EU POPs Regulation: listing under way, in-force status not confirmed
- MCCPs are listed in Annex A (Elimination) of the Stockholm Convention [10].
- ECHA's list of substances under the EU POPs Regulation has no MCCP entry in the data I searched.
- On EUR-Lex, a Commission draft delegated act (search snippet only) would add MCCP to Annex I Part A of Regulation (EU) 2019/1021. It implements COP-12 decision SC-12/10 (May 2025). Exemptions mentioned in the snippet:
- aerospace and defence
- medical devices and in-vitro diagnostic devices
- spare parts and repair of articles
- I found no official source giving its Official Journal publication, application date or concentration limits. Once it applies, an Annex I Part A listing means a ban on placing on the market, including in articles, unless an exemption applies. That would go further than the Candidate List duties.
4. Your duties now
| Duty | Trigger | What you must do |
|---|---|---|
| REACH Art. 33(1) | Article contains a Candidate List substance above 0.1% w/w | Give the recipient enough information for safe use, at least the substance name [11] |
| REACH Art. 33(2) | Same, when a consumer asks | Provide the same information free of charge within 45 days [11] |
| SCIP (Waste Framework Directive Art. 9(1)(i)) | Any supplier of an article with Art. 33(1) information, from 5 January 2021 | Submit that information to ECHA. ECHA's database is open to waste operators, and to consumers on request [12] |
| REACH Art. 7(2) notification | Above 0.1% w/w and more than 1 tonne per year of MCCP in your articles, per producer or importer | Notify ECHA, unless exposure can be excluded or the use is already registered. This applies from six months after Candidate List inclusion [13] |
In practice, measure the MCCP content of the sheath against the 0.1% threshold. If it is above:
- name MCCP in your downstream communication;
- notify the cable sheath, and every electronic product that contains it, in SCIP;
- check your annual tonnage against the Art. 7(2) threshold.
Given the POPs listing in progress and the Annex XVII dossier, the sheath compound is also the obvious candidate for substitution. The dossier lists technically feasible alternative plasticisers and flame retardants for PVC cables [14].
I can also check whether MCCP has been added to RoHS Annex II. The restriction dossier cites a 2018 Swedish (KEMI) proposal to restrict MCCP under RoHS.
Sources:
SOURCES · 14
- [1]Medium-chain chlorinated paraffins (MCCP) · p.2SVHC
- [2]D(2021)4569-DC · p.1SVHC
- [3]Alkanes, C14-17, chloro · p.2SVHC
- [4]Alkanes, C14-16, chloro · p.2SVHC
- [5]Tetradecane, chloro derivs. · p.2SVHC
- [6]di-, tri- and tetrachlorotetradecane · p.2SVHC
- [7]Medium-chain chlorinated paraffins (MCCP) and other substances that contain chloroalkanes with carbon chain lengths within the range from C14 to C17 · p.92Annex XVII
- [8]Medium-chain chlorinated paraffins (MCCP) and other substances that contain chloroalkanes with carbon chain lengths within the range from C14 to C17 · p.20Annex XVII
- [9]Medium-chain chlorinated paraffins (MCCP) and other substances that contain chloroalkanes with carbon chain lengths within the range from C14 to C17 · p.24Annex XVII
- [10]Medium-chain chlorinated paraffins (MCCPs) (Annex A) · p.1BRS
- [11]Article 33: Duty to communicate information on substances in articles [REACH 02006R1907-20260511] · p.1REACH
- [12]02008L0098-20251016 articleEU
- [13]Article 7: Registration and notification of substances in articles [REACH 02006R1907-20260511] · p.1REACH
- [14]Medium-chain chlorinated paraffins (MCCP) and other substances that contain chloroalkanes with carbon chain lengths within the range from C14 to C17 · p.45Annex XVII