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December 2024 European Chemicals Monthly Bulletin

Time: 2025-01-02

Read: 144

I. Update on the Progress of PFAS Restrictions in Europe

On November 20, 2024, the European Chemicals Agency (ECHA), together with five relevant competent authorities (dossier submitters), updated the progress report on the restriction of per- and polyfluoroalkyl substances (PFAS) in Europe. The core contents include:

  1. Expansion of covered restricted uses: Clarified uses not mentioned in the initial restriction draft, such as technical textiles, sealing, punting, and medical applications, with special attention to fluoropolymers;

  2. Exploration of alternative restriction schemes: Instead of focusing solely on "full bans" or "phased bans", more alternative restriction options are being explored based on the availability of substitutes.

In addition, on November 8, 2024, the European Commission issued an initiative related to chemical contaminants - Limit Values and Exemptions for Perfluorooctanoic Acid (PFOA), aiming to seek comments on "delaying the date of banning fire-fighting foams" and propose new concentration limit requirements for "unintentionally present trace contaminants".

II. New Requirements for Substances and Mixtures (Revision of CLP Regulation)

On November 20, 2024, the European Commission issued Regulation (2024/2865), which amends Regulation (EC) No 1272/2008 on the Classification, Labelling and Packaging of Substances and Mixtures (referred to as the "CLP Regulation" for short). This amended regulation officially came into force on December 10, 2024, and the application dates for each clause are as shown in the table below:

Category of Regulation ChaptersContent of Relevant ProvisionsApplication Date
Part I: General IssuesArticle 1 (Objectives and Scope)January 1, 2027

Article 2 (Definitions)December 10, 2024

Article 4 (General Obligations for Classification, Labelling and Packaging)July 1, 2026
Part II: Hazard ClassificationArticle 5 (Identification and Review of Available Information on Substances), Article 6 (Identification and Review of Available Information on Mixtures)July 1, 2026

Article 9 (Evaluation of Hazard Information on Substances and Mixtures), Article 10 (Concentration Limits and M-Factors for the Classification of Substances and Mixtures)July 1, 2026

Article 13 (Decisions on the Classification of Substances and Mixtures)December 10, 2024
Part III: Hazard Communication in the Form of LabellingArticle 18 (Product Identifier)January 1, 2027

Article 23 (Exemptions from Labelling Requirements in Special Cases)December 10, 2024

Article 24 (Applications for the Use of Alternative Chemical Names)July 1, 2026

Article 25 (Supplementary Information on Labels)December 10, 2024

Article 29 (Exemptions from Labelling and Packaging Requirements), Article 30 (Updating of Label Information)July 1, 2026

Article 31 (Paragraphs 1, 1a, 1b, General Rules for the Application of Labels)July 1, 2026

Article 31 (Paragraph 3, General Rules for the Application of Labels)January 1, 2027

Article 32 (Position of Information on Labels)December 10, 2024

Article 34a (Physical and Digital Labels, Newly Added), Article 34b (Requirements for Digital Labels, Newly Added)July 1, 2026
Part IV: PackagingArticle 35 (Packaging)July 1, 2026
Part V: Harmonization of Classification and Labelling of Substances and Classification and Labelling ListArticle 36 (Harmonization of Classification and Labelling of Substances), Article 37 (Procedure for the Harmonization of Classification and Labelling of Substances), Article 38 (Content of Opinions and Decisions on Harmonized Classification and Labelling in Part 3 of Annex VI; Accessibility of Information)December 10, 2024

Article 40 (Obligation to Notify the Agency), Article 42 (Classification and Labelling List)July 1, 2026
Part VI: Competent Authorities and EnforcementArticle 45 (Designation of Bodies Responsible for Receiving Information Related to Emergency Health Responses)January 1, 2027

Article 46 (Enforcement and Reporting)December 10, 2024
Part VII: Common and Final ProvisionsArticle 48 (Advertising), Article 48a (Distance Selling Offers, Newly Added)July 1, 2026

Article 50 (Tasks of the Agency), Article 52 (Safeguard Clause), Article 53 (Adaptation to Technical and Scientific Progress), Article 53a (Exercise of Powers of Authorization), Article 53c (Separate Authorization Acts for Different Authorization Powers), Article 54 (Committee Procedure), Article 54a (Reporting and Review, Newly Added), Article 61 (Transitional Provisions)December 10, 2024
Annex I: Classification and Labelling Requirements for Hazardous Substances and MixturesSection 1.1.1.3 of Part 1 (Role and Application of Expert Judgment and Determination of the Weight of Evidence)December 10, 2024

Section 1.2.1.4 of Part 1 (Table 1.3 - Minimum Sizes of Labels and Pictograms and Minimum Font Sizes), Section 1.2.1.5 of Part 1 (Characteristic Text on Labels)January 1, 2027

Section 1.2.1.6 of Part 1 (Folded Labels)July 1, 2026

Section 1.3.7 of Part 1 (Ammunition, Newly Added), Section 1.5.1 of Part 1 (Exemptions from Article 31 under Paragraph 1 of Article 29), Section 1.5.1.1 of Part 1 (Exemptions from Article 31 (Paragraph 1 of Article 29))December 10, 2024

Section 1.5.1.2 of Part 1 (Exemptions from Article 31 (Paragraph 1 of Article 29)), Section 1.5.2.4.1 of Part 1 (Label Elements Required by Article 17), Section 1.6 of Part 1 (Label Elements That May Only Be Provided on Digital Labels, Newly Added)July 1, 2026
Annex II: Special Rules for the Labelling and Packaging of Certain Substances and MixturesSection 3.4 of Part 3 (Supply through Refill Stations), Part 5 (Hazardous Substances and Mixtures to Which Paragraph 3 of Article 29 Applies)July 1, 2026
Annex VI: Harmonized Classification and Labelling of Certain Hazardous SubstancesPart 2 (Dossiers for Harmonized Classification and Labelling)December 10, 2024
Annex VIII: Harmonized Information on Emergency Health Responses and Preventive MeasuresSection 1 of Part A (General Requirements) (Application), Section 2.1 of Part A (Objectives, Scope and Definitions), Section 2.4 of Part A (Definitions); Section 1.1a of Part B (Information in Submissions) (Name and Product Description of Standard Formulations or Fuel Names, Newly Added), Section 3.1 of Part B (General Requirements), Section 3.6 of Part B (Mixtures Whose Components Conform to Standard Formulations), Section 3.7 of Part B (Fuels), Section 4.1 of Part B (Submission Updates); Section 1.2 of Part C (Submission Format) (Identification of Mixtures, Submitters and Contact Points), Section 1.4 of Part C (Information on Mixture Components and Interchangeable Component Groups); Part D (Standard Formulations) (Cement, Gypsum Binders, Ready-Mixed Concrete)January 1, 2027

III. Release of the New Version of CLP Standard Application Guidelines

On November 13, 2024, the European Chemicals Agency (ECHA) released 5 documents related to the application of the CLP Standard (Classification, Labelling and Packaging Standard for Substances and Mixtures), aiming to provide detailed guidance for the application of the CLP Standard to substances with "physical hazards, health hazards, and environmental hazards". The specific documents include:

  1. Overview of the CLP Standard Application Guidelines Series [PDF]

  2. Part 1: General Principles of Classification and Labelling [PDF]

  3. Part 2: Physical Hazards [PDF]

  4. Part 3: Health Hazards [PDF]

  5. Part 4/5: Environmental Hazards and Other Hazards [PDF]

IV. European Chemicals-Related Registration and Consultation Platforms (Summary of ECHA Links)

  1. Classification and Labelling Harmonization (CLH) Intent Registration (until outcome announcement): [Registry of CLH intentions until outcome - ECHA (europa.eu)]

  2. Harmonized Classification and Labelling Consultations: [Harmonised classification and labelling consultations - ECHA (europa.eu)]

  3. Restriction Intent Registration (until outcome announcement): [Registry of restriction intentions until outcome - ECHA (europa.eu)]

  4. Substances of Very High Concern (SVHC) Intent Registration (until outcome announcement): [Registry of SVHC intentions until outcome - ECHA (europa.eu)]

  5. Substance Evaluation (CoRAP): [Substance evaluation - CoRAP - ECHA (europa.eu)]

  6. Adopted Opinions and Previous Consultations on Applications for Authorisation: [Adopted opinions and previous consultations on applications for authorisation - ECHA (europa.eu)]

  7. Applications for Authorisation (Current Consultations): [Applications for authorisation - current consultations - ECHA (europa.eu)]

  8. Current Calls for Comments and Evidence: [Current calls for comments and evidence - ECHA (europa.eu)]

  9. Authorisation List: [Authorisation List - ECHA (europa.eu)]

  10. Completed Restriction Activities by ECHA

  11. Submitted Restriction Proposals Pending Consideration

  12. Regulatory Need Assessment List

V. Chemical-Related Developments in Other Countries

(I) United Kingdom: 2024 Persistent Organic Pollutants (POPs) Proposal

On October 28, 2024, the UK Department for Environment, Food and Rural Affairs (DEFRA) launched a call for information on the Draft Risk Profile and Draft Risk Management Evaluation for two substances proposed to be classified as "Persistent Organic Pollutants (POPs)". This classification is based on the United Nations Stockholm Convention, and the substances involved include:

  1. Polyhalogenated dibenzo-p-dioxins and dibenzofurans (PXDD/Fs)

  2. Chlorinated paraffins with a carbon chain length in the C14-17 range

(II) Brazil: New Regulations on Chemical Management Law

On November 14, 2024, the Brazilian government issued Law No. 15022 of November 13, 2024 (related to chemical management). With the goal of "reducing adverse impacts on health and the environment", this law establishes a "National List of Chemical Substances" and implements risk assessment and risk control for "chemicals used, produced, or imported within Brazil", while including other relevant provisions.

1. Core Requirements

  • Registration Requirement: If the annual production or import volume of a substance reaches 1 ton or more, chemical registration is required;

  • Safety Data Sheet (SDS): Must comply with the Globally Harmonized System (GHS) standards;

  • Risk Assessment: Risk assessment analysis must be conducted based on the recommended use of the substance;

  • Substance Identification: Identification information of the substance (such as CAS number) must be provided.

2. Implementation Timeline

Time NodeImplementation Content
November 15, 2024The law officially comes into force
May 15, 2024Issuance of the implementing regulations of this law
November 15, 2027Official establishment of the registration system platform required for the implementation of the "National List of Chemical Substances"
November 15, 2030Final registration deadline

This law is aligned with the international chemical management framework (REACH Regulation).

VI. Developments Related to Sustainable Development, Circular Economy and the Environment

The following is a summary of important recent releases (non-exhaustive) in the fields of sustainable development, circular economy, and the environment:

Issuing AuthorityRelease DateRelease Content and Core Points
Direction Générale de la Concurrence, de la Consommation et de la Répression des Fraudes (DGCCRF), FranceSeptember 18, 2024Released the Eco-Transition Support press kit, covering:- Consumption (key data)- Energy labels- Furniture and equipment recycling- Strengthened penalties for energy renovation fraud- Support for the evolution of consumption patterns- Assistance in regulation formulation
DGCCRF, FranceSeptember 4, 2024Released the Practical Guide to Greenwashing Risks, including recommendations and supporting videos, aiming to warn about the hazards of greenwashing practices.
French Ministry for Ecological TransitionOctober 20, 2024Issued Decree of October 8, 2024, amending the Decree of December 12, 2022 on Extended Producer Responsibility (EPR) Industry Data, adding 3 annexes to clarify the specific data transmission processes for "approved eco-organizations" in the following EPR industries:- Packaging for the sale of "products for professional consumption/use"- Tyres- Passenger cars, vans, and two/three-wheeled vehicles (corresponding to Paragraphs 2, 15, and 16 of Article L.541-10-1 of the Environmental Code respectively)
Autorité de Régulation de la Publicité Professionnelle (ARPP), FranceOctober 20, 2024Released Sustainable Development Recommendations, aiming to comply with the principles of the United Nations Development Programme (UNDP) Sustainable Development Goals (SDGs), covering multiple dimensions of sustainable development: economic growth, social inclusion, and environmental protection.
European CommissionOctober 23, 2024Issued Implementing Regulation (EU) 2024/2729 of October 22, 2024, which, in accordance with Regulation (EU) 2024/573 of the European Parliament and of the Council, authorizes exemptions for the "use of fluorinated greenhouse gases in specific environmental simulation equipment, laboratory spray drying/freeze-drying equipment, and laboratory centrifuges".
European CommissionOctober 29, 2024Released Draft Act Amending Regulation (EC) No 477/2001 on Packaging and Related Regulations (Czech proposal, No. 2024/0591/CZ), proposing to introduce a deposit system for "selected single-use beverage packaging", including plastic beverage bottles and metal beverage containers (especially cans).
Council of the European UnionNovember 5, 2024Officially adopted the Revised Regulation on European Environmental Economic Accounts, aiming to better measure "the contribution of the environment to the economy".
European CommissionNovember 7, 2024Released Communication on the Strategic Framework for Engagement in International Cooperation in the Context of Regulation (EU) 2023/1115 (Relating to the Placing on the Market and Export of Defforestation-Free Products in the EU).
French Ministry for Ecological Transition, French Ministry of Economy, Finance and IndustryNovember 10, 2024Issued Decree of October 21, 2024 (Text No. 9), which, in accordance with Article L.541-10 of the Environmental Code, approved the "Extended Producer Responsibility (EPR) Industry Coordination Body for DIY and Gardening Supplies". OCABJ was authorized as the coordination body, responsible for coordinating the joint work of various eco-organizations and allocating obligations, with a validity period until December 31, 2027 (Note: If there are multiple approved eco-organizations in the same product category, the establishment of a coordination body may be required).
European CommissionNovember 13, 20