December 19, 2024 by Rhiannon Smith
New hazard criteria were introduced under the Classification Labelling and Packaging (CLP) Regulation in April 2023 for Persistent, Bioaccumulative and Toxic (PBT) / very Persistent, very Bioaccumulative (vPvB), Persistent, Mobile and Toxic (PMT) / very Persistent, very Mobile (vPvM) and Endocrine Disruption (ED). Guidance on the application of the new criteria was issued in November 2024. However, there has previously been some uncertainty regarding the application of the timelines for the new CLP criteria.
- For substances placed on the market before 1 May 2025, the new hazard criteria are mandatory from 1 November 2026
- For substances placed on the market after 1 May 2025, the new hazard criteria are mandatory from 1 May 2025
Many industry groups were uncertain whether the term ‘substances placed on the market’ referred to the availability of a REACH registration allowing a company the right to sell a substance on the EU market or to the individual quantities of a substance that are made available for sale.
The ECHA website has recently been updated to address this uncertainty and has clarified that substance placed on the market refers to “substances placed on the market on or after 1 May 2025, or new quantities of substances placed on the market before 1 May 2025, when the new quantity is placed on the market on or after 1 May 2025”.
Therefore, companies should be aware that from 1 May 2025, all individual batches of a substance which are made available for sale (i.e. a container of the substance which is ‘placed on the shelf’) need to address the new CLP criteria.
wca have a wealth of experience in ED, PBT and PMT specific assessments, as well as the application of REACH and CLP. If you would like assistance with any of these topics, please contact us.
From our blog
December 19, 2024 by Rhiannon Smith