The European Union has published significant updates to its CLP (classification, labeling, and packaging) regulations, impacting chemical substances, particularly concerning endocrine disruptors (ED), persistent bioaccumulative toxins (PBT), and mobile toxic substances (PMT). These updates introduce new hazard classes, expand harmonized classification procedures, and integrate digital labeling. These amendments are aimed at enhancing safety standards and responding to emerging environmental and health risks, including endocrine disruption.
Key Changes in the CLP Amendment
The updated CLP now includes five new hazard classes: endocrine disruptors, PBT, very persistent bioaccumulative substances (vPvB), PMT, and very persistent mobile (vPvM) substances. These classes will now be prioritized for classification and labeling, streamlining the process for substances that meet these criteria, particularly in relation to the REACH Candidate List. Notably, the amendment introduces the possibility for the European Commission to initiate a harmonized classification procedure, facilitating quicker classification of substances, especially if they are suspected of having PBT, ED, or other concerning properties. Companies will now have to update classifications within six months rather than the previous 18-month deadline. The amendment also allows for the use of digital labels, providing an alternative method for companies to meet labeling requirements without compromising public health and safety.
Focus on Endocrine Disruption and New Guidelines
A major aspect of the amendment is its focus on endocrine disruptors (ED), chemicals that can interfere with the body’s hormone system. The European Chemicals Agency (ECHA) has published new guidance to help industry stakeholders classify substances based on their ED potential. However, the guidance has been criticized for its complexity and lack of clarity, particularly regarding what constitutes an ED substance. The guidelines reference existing frameworks from biocide and plant protection regulations but do not provide specific examples to help industry professionals classify substances. This uncertainty may lead to companies erring on the side of caution and classifying more substances as suspected EDs (Category 2).
Digital Labels and Modernization
In a bid to modernize the system, the CLP amendment introduces the option of digital labels, which can be accessed through data carriers like QR codes. This move is in line with the EU’s push to innovate labeling methods while ensuring essential hazard information is still readily available to consumers and professionals. However, digital labels will only be permitted for non-essential information not directly tied to health or environmental safety.
Concluding Remarks
The new regulatory changes set the stage for a more robust system for classifying chemicals, especially those with significant environmental and health risks such as PFAS and AFFF. As the EU continues to refine its approach to emerging contaminants, companies should stay vigilant in understanding and complying with these updates. Businesses involved with chemicals, especially those in the hazardous material or environmental remediation sectors, should review the guidance and amend their practices to ensure they meet the updated regulations. While the full enforcement of these changes will take time, industry leaders should act now to stay ahead of potential regulatory hurdles.
