CLP revision: the introduction of hazard classes for endocrine disruptors.

Endocrine disruption classification in the EU is planned, in the frame of the CLP regulation revision, to be divided between the two key target areas:

  • human health
  • environment

Both hazard classes will then be further split into two hazard categories based on level of evidence (as for CMR1 classification):

  • Category 1 for known or presumed endocrine disruptors
  • Category 2 for suspected endocrine disruptors.

The Commission’s European Green Deal2 sets a high ambition for zero pollution leading to a toxic-free environment. One of the first deliverables is the Chemicals Strategy for Sustainability: Towards a Toxic-free Environment3 adopted on 14 October 2020. The objectives of the strategy are to achieve a legitimate higher level of protection of citizens and of the environment against hazardous chemicals. To achieve these objectives, the Chemicals Strategy for Sustainability sets out several actions that require a targeted revision of Regulation (EC) No 1272/2008 on hazard classification, labelling and packaging of chemicals (the CLP Regulation).  Various options for revision will be analysed in an impact assessment4 and, based on the results, the Commission will present legislative proposals, at the end of 2021, for a revision of both the enacting terms of and the annexes to that Regulation.

It has been identified by the Commission’s European that the CLP Regulation, as the core piece of Union legislation for the hazard assessment of chemicals, stemming from the United Nations’ global standard (GHS), has not kept up with scientific or technological progress, or with (on-line) market developments. In other aspects, the Regulation is ambiguous and allows for diverging interpretations. Among the topics identified there is an issue about “incomplete information about hazards to human health and the environment”. Therefore, among the major changes in CLP planned and already announced for 2022 by the European Commission, the introduction of new hazard classes for endocrine disruptors has been identified as a priority. The labeling obligations about endocrine disruptions could thus be extended to categories of products which are not currently concerned.

The main lines of proposal are about the use of separate hazard classes for endocrine disruptors for human health and environment and the Introduction of categories based on the endocrine disruption hazard level. But the criteria need to be set. The consultations are planned to occur on existing CLP-relevant fora, such as the Commission’s expert group Caracal, its subgroup on endocrine disruptors, and ECHA’s enforcement forum, Helpnet network, and expert groups. 

The Drafting proposal for revision of CLP should be published in September 2021 and the Commission adoption of proposal is planned for the end 2021. 

Do not hesitate to contact us for further information: Aurély BEGHIN abeghin@staphyt.com

1 carcinogenic, mutagenic, or toxic for reproduction substances
2 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52019DC0640
3 https://ec.europa.eu/environment/pdf/chemicals/2020/10/Strategy.pdf
4 Initiative details
5 https://unece.org/about-ghs