Version 8.4
🔁 Launching 25 July 2025
BOMcheck will be updated to Version 8.4 to include three new SVHCs and other new substance categories detailed below. Upon release, BOMcheck will provide a 30-minute video explaining what types of materials and parts may contain the new declarable substances and how to update your Regulatory Compliance Declarations (RCDs).
Version Summary
- Packaging Declaration tool update & improvements
- 3 new SVHCs added to the REACH Candidate List on 25 June 2025
- New Substances of Concern entry on the Industry Restricted and Declarable list
- Support for ESRS E2-5 substance requirements
- Support for EU Taxonomy Do No Significant Harm (DNSH)
- New entries to the POPs Stockholm Convention list and updates to existing entries
- Amendment to Bisphenol A in Food Contact Materials entry to include additional hazardous bisphenols and derivatives
- Updates to the CMR 1A & 1B list of substances
- Updates to RoHS exemption expiry dates
Resources (XMLs, CSV & PDFs)
BOMcheck v8.4 Downloads
Indicative XMLs and reference substance lists will be provided on: 14/07/2025
Packaging Declaration Tool Update
We’ve enhanced and streamlined compliance declarations by migrating the Packaging Declaration Tool into the Regulatory Compliance Declaration (RCD) Tool. This integration provides a more powerful, future-ready solution for suppliers and manufacturers. Existing sales packaging declarations can now be updated and expanded using BOMcheck's new and improved RCD tool with additional benefits:
- Unified Toolset: Declare packaging part and material compliance using the same - new and improved - unified declaration toolset.
- Full Packaging Scope: Make declarations for all packaging levels:
- Primary (Sales packaging)
- Secondary (Grouped packaging)
- Tertiary (Transport packaging)
- Expanded Regulatory Coverage: Access BOMcheck’s extensive regulatory content (DSLs), now reassessed and extended to include packaging-specific legislation.
- Circularity Data Capture: Packaging declarations can now include important Extended Producer Responsibility (EPR) and circularity data.
- Future-Proof Compliance: Be prepared for upcoming legislation such as PFAS restrictions on packaging.
- Search & Export Packaging: Compliance search tools can now retrieve packaging declarations directly for assessment and export in industry standard IPC formats for integration with other business systems.
Substance Details
New REACH Candidate List Substances
ECHA updated the REACH Candidate List (which now contains 250 substances) on 25 June 2025, to add a total of 3 new SVHCs.
| Substance name and CAS number | Example of use(s) |
|---|---|
| 1,1,1,3,5,5,5-heptamethyl-3- [(trimethylsilyl)oxy]trisiloxane (M3T), CAS: 115-86-6 | Surface treatments and coatings. |
| decamethyltetrasiloxane (L4), CAS: 141-62-8 | Lubricants and greases, surface treatments and heat transfer fluid. |
| tetra(sodium/potassium)-7-[(E)-{2- acetamido-4-[(E)-(4-{[4-chlor-6-({2-[(4-f luor-6-{[4-(vinylsulf onyl)phenyl]amino}- 1,3,5-triazin-2-yl)amino]propyl}amino)-1,3,5- triazin-2-yl]amino}-5-sulf onato-1-naphthyl)diazenyl]-5- methoxyphenyl}diazenyl]-1,3,6-naphthalin, CAS: None provided | Reactive dye used in textiles. |
New Substances of Concern entry on Industry Restricted or Declarable Substances
To assist with compliance to the ESRS and EU Taxonomy regulations an entry covering Substances of Concern has been added to the Industry Restricted and Declarable Substances List in BOMcheck.
Substances of Concern are defined as substances in specific hazard classes or hazard categories in Part 3 of Annex VI to Regulation (EC) No 1272/2008 (CLP) and are subject to disclosure requirements.
A list of 3,531 individual substances with CAS numbers meeting these criteria are included within the new entry.
The BOMcheck RCD CAS Checker functionality reduces the workload on suppliers to declare against these large substance lists.
POPs Stockholm Convention list update and national implementations
Two new substance groups have been recommended to be listed for elimination under the Stockholm Convention. New entries for these substances have been added to the POPs Stockholm Convention List in BOMcheck:
- Chlorinated Paraffins with carbon chain lengths in the range of C14-17 and Chlorination Levels ≥ 45% Chlorine by Weight
- Long-chain Perfluorocarboxylic Acids (LC-PFCAs), their salts, and related compounds
The entry for PFOS has been updated to ensure alignment with updates to the schedule 7 of the IchEMS Register in Australia and an EU POPs amendment. The previous entry has been split into two new entries with thresholds to include limits on Unintentional Trace Contaminants:
- PFOS and its salts: 0.025 mg/kg (25 ppb) UTC limit
- PFOS-related compounds: 1 mg/kg (1 ppm) UTC limit for individual or sum
On 18 February 2025, the EU Commission initiated a public consultation on two proposals to address the regulation of Polychlorinated biphenyls (PCB) and polybrominated diphenyl ethers (PBDEs). The threshold for these two entries has been amended to the following:
- Polychlorinated biphenyls (PCBs): 0.2 mg/kg (0.2 ppm) UTC limit for the sum of PCBs in substances, mixtures and articles
- Polybrominated diphenyl ethers (PBDEs): 10 mg/kg (10 ppm) UTC limit for the sum of PBDEs in mixtures and articles
On 5th May 2025, the EU Commission adopted an amendment to EU POPs legislation to list UTC limits for UV-328. The threshold for this entry has been amended to the following:
- UV-328: 1 mg/kg (1 ppm) UTC limit
To ensure alignment with the UTC limit included under EU POPs legislation, the entry for Pentachlorophenol has been updated to the following:
- Pentachlorophenol (PCP) its salts and esters: 5 mg/kg (5 ppm) UTC limit
Amendment to Bisphenol A in Food Contact Materials
On December 31, 2024, the EU issued Commission Regulation (EU) 2024/3190 on the use of BPA (CAS 80-05-7) and other bisphenols and bisphenol derivatives with harmonized classification for specific hazardous properties in certain Food Contact Materials and articles.
The entry for Bisphenol A in food contact materials included on the Other Restricted and Declarable Substances list has been updated to include the following substances:
| Substance name and CAS number | Classification |
|---|---|
| Bisphenol A (BPA), CAS: 80-05-7 | Repr. 1B |
| Bisphenol AF (BPAF), CAS: 1478-61-1 | Repr. 1B |
| TBBPA: 4,4′-(isopropylidene)bis(2,6-dibromophenol), CAS: 79-94-7 | Repr. 1B |
| Bisphenol S, CAS: 80-09-1 | Repr. 1B |
| 4,4-isobutylethylidenediphenol, CAS: 6807-17-6 | Repr. 1B |
Updated EU MDR (CMR 1A & 1B) substances
The CMR 1A & 1B substances list in the RCD tool has been updated to include additional substances from REACH Candidate List. Due to the updated list, the entry for CMR 1A & 1B substances in the RCD tool will be set to missing for all applicable suppliers.
Updates to RoHS exemptions
- Expiry (on 21/11/2025) of Cadmium exemption for all equipment categories:
- Annex III – 39a
- Expiry (on 31/12/2025) of Lead exemption for all equipment categories:
- Annex IV – 37
Updates to threshold calculation levels and threshold statements
To ensure full alignment with regulatory requirements, BOMcheck has updated the threshold calculation levels for certain substances. These changes ensure that the calculation method used in declarations now exactly matches the threshold statements defined by the applicable regulations.
Updating Declarations
After the release of v8.4 the BOMcheck team will publish a guidance webinar giving step-by-step instructions on how users can update RCDs in BOMcheck. Suppliers that have made FMDs do not need to take any action.