Chemicals | Monthly bulletin | December 2024

Eurofins newsflash Chemical

Europe

Update of the process about PFAS restriction

On the 20^th of November 2024, the European Chemicals Agency (ECHA), along with the relevant five authorities (dossier submitters), updated its report on the process to restrict per- and polyfluoroalkyl substances (PFAS) in Europe.

This update identifies several uses not mentioned in the initial draft of restriction, such as technical textiles, sealing, punting and medical applications, and special attention to fluoropolymers. Another important point is that further restriction options are being explored as an alternative to a complete ban or phased ban, depending on the availability of alternatives.

In addition, on the 8^th of November 2024, the European Commission published an initiative related to Chemical pollutants – limits and exemptions for perfluorooctanoic acid (PFOA). The aim of this publication is to invite comments on the postponement of the date of the ban of fire-fighting foams and to propose new concentration limits for unintentional trace contaminants.

For more information, consult the official news in ECHA’s website here.

New requirements for substances and mixtures

On the 20^th of November 2024, the European Commission published Regulation 2024/2865, which amends Regulation (EC) No 1272/2008, on the classification, labelling and packaging of substances and mixtures.

The amendments affect the following articles:

Title I – General Issues		Application date
	Article 1 Purpose and scope	01/01/2027
	Article 2 Definitions	10/12/2024
	Article 4 General obligations to classify, label and package	01/07/2026
Title II – Hazard classification
Chapter 1 Identification and examination of information	Article 5 Identification and examination of available information on substances Article 6 Identification and examination of available information on mixtures	01/07/2026
Chapter 2 Evaluation of hazard information and decision on classification	Article 9 Evaluation of hazard information for substances and mixtures Article 10 Concentration limits and M-factors for classification of substances and mixtures	01/07/2026
	Article 13 Decision to classify substances and mixtures	10/12/2024
Title III – Hazard communication in the form of labelling		>
Chapter 1 Content of the label	Article 18 Product identifiers	01/01/2027
	Article 23 Derogations from labelling requirements for special cases	10/12/2024
	Article 24 Request for use of an alternative chemical name	01/07/2026
	Article 25 Supplemental information on the label	10/12/2024
	Article 29 Exemptions from labelling and packaging requirements Article 30 Updating information on labels	01/07/2026
Chapter 2 Application of labels	Article 31 (paragraph 1, 1a and 1b) General rules for the application of labels	01/07/2026
	Article 31 (paragraph 3) General rules for the application of labels	01/01/2027
	Article 32 Location of information on the label	10/12/2024
	Article 34a Physical and digital labelling (new) Article 34b Requirements for digital labelling (new)	01/07/2026
Title IV: Packaging
	Article 35 Packaging	01/07/2026
Title V: Harmonisation of classification and labelling of substances and the classification and labelling inventory
Chapter 1 Establishing harmonised classification and labelling of substances	Article 36 Harmonisation of classification and labelling of substances. Article 37 Procedure for harmonisation of classification and labelling of substances. Article 38 Content of opinions and decisions for harmonised classification and labelling in Part 3 of Annex VI; accessibility of information.	10/12/2024
Chapter 2 Classification and labelling inventory	Article 40 Obligation to notify the Agency Article 42 The classification and labelling inventory	01/07/2026
Title VI: Competent authorities and enforcement
	Article 45 Appointment of bodies responsible for receiving information relating to emergency health response	01/01/2027
	Article 46 Enforcement and reporting	10/12/2024
Title VII: Common and final provisions
	Article 48 Advertisement Article 48a Distance sales offers (new)	01/07/2026
	Article 50 Tasks of the Agency Article 52 Safeguard clause Article 53 Adaptations to technical and scientific progress Article 53a Exercise of the delegation Article 53c Separate delegated acts for different delegated Powers Article 54 Committee procedure Article 54a Reporting and review (new) Article 61 Transitional provisions	10/12/2024
Annex I: classification and labelling requirements for hazardous substances and mixtures
	Part 1: General principles for classification and labelling Section 1.1.1.3: The role and application of expert judgement and weight of evidence determination	10/12/2024
	Section 1.2.1.4: Table 1.3 - Minimum dimensions of labels and pictograms and minimum font size Section 1.2.1.5. The characteristic text on the label.	01/01/2027
	Section 1.2.1.6. Fold-out labels	01/07/2026
	Section 1.3.7. Ammunition (new) Section 1.5.1. Exemptions from Article 31 in accordance with Article 29(1) Section 1.5.1.1 Exemptions from Article 31 [(Article 29(1))]	10/12/2024
	Section 1.5.1.2 Exemptions from Article 31 [(Article 29(1))] Section 1.5.2.4.1. The label elements required by Article 17. Section 1.6. Label elements that may be provided on a digital label only (new)	01/07/2026
Annex II - special rules for labelling and packaging of certain substances and mixture
	Part 3: Special rules on packaging. Section 3.4. Supply via refill stations Part 5: Hazardous substances and mixtures to which article 29(3) applies	01/07/2026
Annex VI - Harmonised classification and labelling for certain hazardous substances
	Part 2: dossiers for harmonised classification and labelling	10/12/2024
Annex VIII - harmonised information relating to emergency health response and preventative measures
	Part A - general requirements : Section 1. Application Section 2.1 Purpose, scope and definitions Section 2.4 Definitions Part B- information contained in a submission : 1.1a. Name and product description of standard formula or name of fuel (New) Section 3.1 General requirements Section 3.6. Mixtures with a composition conforming with a standard formula Section 3.7 Fuels Section 4.1 Submition update Part C – Submission format: Section 1.2 Identification of the mixture, submitter and contact point Section 1.4 Information on the mixture components and interchangeable component groups Part D – Standard formulas Cement Gypsum binder Ready mixed concrete	01/01/2027

This Regulation entered into force on the 10^th of December 2024.

For more information, consult the official publication in European Commission website here.

New version of guidelines on the Application of CLP criteria

On the 13^th of November 2024, the European Chemical Agency published the following five documents related to the application of the CLP Criteria:

The objective of these documents series is to provide detailed guidance on the application of the CLP criteria for physical, health and environmental hazards.

Interesting resources on the CLP Regulation on ECHA’s website

Interesting resources on the REACH Regulation on ECHA’s website

Substances proposed as persistent organic pollutants (POPs) 2024

On the 28^th of October 2024, the Department for Environment, Food and Rural Affairs requested information for a draft Risk Profile and Risk Management Evaluation for two substances proposed as persistent organic pollutants (POPs) according to the United Nations’ Stockholm Convention.

The substances are:

Polyhalogenated dibenzo-p-dioxins and dibenzofurans (PXDD/Fs)
Chlorinated paraffins with carbon chain lengths in the range C14-17

For more information, consult the UK government website here.

Brazil

Brazilian Chemical Management Law

On the 14^th of November 2024, the Brazilian government published Law No. 15,022 of November 13, 2024 related to Chemical Management.

It establishes the National Inventory of Chemical Substances and the assessment and risk control of chemical substances used, produced, or imported in the national territory, with the aim of minimising adverse impacts on health and the environment, along with other provisions.

The main points are:

A chemical Registration if an annual subtance's production or import quantity of one ton or more.
Safety Data Sheet (SDS) complies with GHS(Global Harminized System).
A risk assessment analysis studies conducted according to recommended uses.
Identification and information about the substance (for example: CAS number)

Implementation timeline
15/11/2024	Came into effect
15/05/2024	Publication of implementation regulations of this law
15/11/2027	Registration system platform will be officially established for the implementation of the National Inventory of Chemical Substances
15/11/2030	Final registration deadline

This law was development in alignment with the international chemical management framework, REACH.

Sustainability, circular economy and environment

Miscellaneous technical publications relating to environmental, plastics, packaging and waste

The table below summarises the most recent publications regarding sustainability, the circular economy, and the environment (non-exhaustive):

Entity	Date	Publication
French Directorate General for Competition, Consumer Affairs and Fraud Prevention (DGCCRF)	18/09/2024	The DGCCRF published a press kit about la accompagnement la transition écologique where talk about the following points: Consumption: Key figures Energy labelling Return of furniture and equipment Stronger sanctions against fraud in energy renovation Supporting the evolution of consumption patterns Contributing to the development of regulations
French Directorate General for Competition, Consumer Affairs and Fraud Prevention (DGCCRF)	04/09/2024	The DGCCRF published a Practical sheet about the dangers of greenwashing with advices and videos.
French Ministry of Ecological Transition	20/10/2024	Order of October 8, 2024 amending the order of December 12, 2022, relating to data from sectors with extended producer responsibility (EPR). This order supplements the order of 12 December 2022 with three new annexes, which specify the specific transmission procedures to approved eco-organisations on the extended producer responsibility sectors of packaging used to market products consumed or used by professionals, tires and passenger cars, vans, and two- or three-wheeled motor vehicles mentioned respectively in 2°, 15° and 16° of Article L. 541-10-1 of the Environmental Code.
The french professional regulatory body for advertising (ARPP)	20/10/2024	The ARPP published Sustainable development recommendation with the aim of comply with the principles of the UNDP (United Nations Development Program) Sustainable Development Goals, which address the different dimensions of sustainable development: economic growth, social integration, environmental protection.
European Commission	23/10/2024	Commission Implementing Regulation (EU) 2024/2729 of 22 October 2024 authorising an exemption pursuant to Regulation (EU) 2024/573 of the European Parliament and the Council, with regard to the use of fluorinated greenhouse gases in certain environmental simulation devices, laboratory spray-drying or freeze-drying equipment, and laboratory centrifuges.
European Commission	29/10/2024	Draft act amending Act No 477/2001 on packaging and amending certain acts (the Packaging Act), as amended, and other related acts (2024/0591/CZ (Czechia)). The proposed Act introduces a deposit system for selected single-use beverage packaging: plastic beverage bottles and metal beverage containers (especially cans).
European Council	05/11/2024	EU adopts rules to better measure the environment’s contribution to the economy The Council formally adopted the amended regulation on European environmental economic accounts.
European Commission	07/11/2024	Communication from the Commission on the Strategic Framework for International Cooperation Engagement in the context of Regulation (EU) 2023/1115 on the making available on the Union market and the export from the Union of certain commodities and products associated with deforestation and forest degradation
The French Ministry of Ecological Transition and the Ministry of Economy, Finance and Industry	10/11/2024	Order of 21 October 2024 approving a coordinating body for the extended producer responsibility sector of DIY and gardening articles in application of article L. 541-10 of the environmental code (Text No. 9) OCABJ was authorised as a coordinating body responsible for coordinating certain common work of eco-organisations and distributing their obligations until 31 December 2027. According to the principle of extended producer responsibility (EPR), when several eco-organisations are approved for the same category of products, they may be required to set up a coordinating body.
European Commission	13/11/2024	GUIDANCE DOCUMENT for Regulation (EU) 2023/1115 on deforestation-free products
The French Ministry of Ecological Transition and the Ministry of Economy, Finance and Industry	17/11/2024	Order of 30 October 2024 approving an eco-organisation of the sector with extended responsibility for producers of contents and containers of chemical products that may represent a significant risk to health and the environment referred to in paragraph 7 of Article L. 541-10-1 of the Environmental Code (Text No. 13) EcoPAE was authorised as an eco-organisation for the content and containers of chemicals likely to pose a significant risk to health and the environment, fire extinguishers and other devices with a fire-fighting function from 1 January 2025 to 31 December 2027