endocrine disruptors eu legislation ghs clp

CLP: New Endocrine Disruption Hazard Classes and Criteria

The European Commission has begun consulting on its fast-tracked plans to add new hazard classes to the CLP Regulation, including a category for ‘suspected’ endocrine disrupting chemicals.

For the purpose of classification, the committee proposes to separate out human health endocrine disrupters from environmental endocrine disruptors as there is the potential for them to have different implications in the downstream legislation.  Both hazard classes will then be further split into two hazard categories with Category 1 for known or presumed endocrine disruptors and Category 2 for suspected endocrine disruptors.

The draft law is now open for a four-week consultation period until 18th October.

Fast-Track Fuss

The fast-tracking of these new hazard classes has come under fire from industry groups who have argued that introducing hazard classes, that have not yet been adopted under the UN Globally Harmonised System (GHS) of classification and labelling of chemicals, deserves the full period of legislative scrutiny.  Many have called for a proper review of the changes and some member state authorities have also questioned whether the Commission’s plans are even legal.

Cefic (the European Chemical Industry Council) stated that changing CLP before GHS was like putting “the cart before the horse”, adding that the changes would have far-reaching consequences on the use of chemicals in many value chains.

Changes to Labels & Safety Data Sheets

The introduction of new hazard classes would require reclassification and updated labelling of all substances, as well as updated Safety Data Sheets and REACH registration dossiers. Once substances are reclassified and relabelled, this would mean that mixtures containing these substances would also have to be reclassified and relabelled.

A series of potential label elements, including Signal Words and P Statements, have been outlined within the proposal but no new pictograms have been indicated as yet.

What are EDCs?

Endocrine Disrupting Chemicals (also referred to as hormone disruptors or EDCs) are synthetic chemicals that are not produced by the human body and that disrupt the normal functioning of humans and animals.

It is suspected that EDCs can cause decreased fertility, hormone-related cancers, behavioural changes, adverse effects on the immune systems, and metabolic disorders.  Such adverse effects could be mediated by mimicking the body’s own hormones or interfere with hormone production, secretion, degradation or transport of hormones in the body.

EDCs are suspected of being capable of acting even at very low doses and sensitive windows of exposure appear to be during critical periods of development (for instance, foetal development and puberty).

The harmful impact that EDCs have on health and the environment has been known for more than 20 years.

How You Can Prepare

This amendment will undoubtedly result in future changes of classification for many substances but no action should be taken until the amendments are actually implemented.

In the mean time, keep informed about the possible implications for your business – register for updates from ECHA  and the European Commission site to stay up-to-date with the latest developments.

Have your say and offer your feedback on the proposals

The Deadline for Comments is the 18th October 2022