"On November 4th, 2025, the UK Health & Safety Executive (HSE) has proposed a draft titled ""REACH – Information collection to support future priority substance recommendations for the UK REACH RP-HP Authorization List Annex 14"" is gathering GB-specific information on the substance RP-HP (reaction products of 1,3,4-thiadiazolidine-2,5-dithione, formaldehyde and 4-heptylphenol, branched and linear). The goal is to help decide whether RP-HP should be recommended for inclusion in Annex 14 of UK REACH (the Authorisation List).
Key points
RP-HP is a UVCB substance that contains ≥0.1% 4-heptylphenol (4-HPbl), an identified endocrine disruptor for the environment and a Substance of Very High Concern (SVHC).
RP-HP entered the UK Candidate List in January 2021 for this reason.
Current knowledge and uncertainties
No UK REACH registrations exist for RP-HP-related EC/CAS numbers.
45 DUINs suggest possible import into GB, but real tonnages are unknown.
EU information indicates no current EU registrations and no EU authorisation applications, suggesting the substance may no longer be widely used or used below the 0.1% threshold.
RP-HP was historically used as a corrosion inhibitor in lubricants, greases, and gear oils — including some consumer products.
Environmental emissions
Estimated emissions in GB: 70–1,050 kg/year of RP-HP.
Estimated emissions of 4-HPbl (depending on concentration): <1–105 kg/year.
Regulatory considerations
Adding RP-HP to Annex 14 may not effectively control risks, because the real concern is 4-HPbl, which may also occur in other substances.
However, listing it could align GB regulation with the EU, reducing administrative burdens for companies operating in both markets.
What HSE is seeking
HSE requests additional GB-specific information, especially:
Actual uses of RP-HP in GB.
Tonnages imported, manufactured, or used.
Whether alternatives have already been adopted.
The Comments are Opened on 4 Nov 2025.
Interested parties are invited to submit comments on this substance within 3 months of the publication date. Information submitted will be used to refine this assessment for consideration in future prioritisation work.
Comments closes on 4 Feb 2026."