On June 5, 2026, the European Chemicals Agency (ECHA) Risk Assessment Committee (RAC) made a historic decision at the RAC-77 meeting to classify trifluoroacetic acid (TFA) and its inorganic salts as PMT (Persistent, Mobile, Toxic) and vPvM (very Persistent, very Mobile) substances for the first time. Based on the RAC-77 meeting minutes, CIRS Group provides the following interpretation.
Background
PMT and vPvM are relatively new hazard categories under the EU CLP Regulation, specifically targeting chemical substances that persist in the environment, readily migrate in water bodies, and are toxic. Unlike traditional persistent organic pollutants (POPs), PMT substances do not necessarily exhibit bioaccumulation, but their high water solubility and mobility enable them to extensively contaminate groundwater and drinking water sources.
As a significant degradation product of PFAS substances, TFA is widely present in:
- Refrigerants (degradation products of HFCs and HFOs)
- Pesticides (degradation of trifluoromethyl-containing pesticides)
- Pharmaceutical and chemical intermediates
- Firefighting foams
Meeting Content
1. Comprehensive Upgrade of TFA Classification
The Committee adopted by consensus the CLH (Harmonized Classification and Labelling) proposal for TFA-related substances submitted by the German Federal Institute for Risk Assessment (BfR). Two substances are involved:
|
Substance |
CAS No. |
EC No. |
Key New Classifications |
|
Trifluoroacetic acid (TFA) ...% |
76-05-1 |
200-929-3 |
Reproductive Toxicity Category 1B, PMT, vPvM, Acute Toxicity Upgrade |
|
Sodium trifluoroacetate[1] and other inorganic salts[2] |
2923-18-4 [1] / - [2] |
220-879-6 [1] / - [2] |
Reproductive Toxicity Category 1B, PMT, vPvM |
Specific Changes to TFA Classification
a) New Classifications:
- Reproductive Toxicity Category 1B (H360Df): May damage the unborn child
- PMT (EUH450): Persistent, Mobile, Toxic substance
- vPvM (EUH451): very Persistent, very Mobile substance
- EUH071: Corrosive to the respiratory tract
b) Adjusted Classifications:
- Inhalation acute toxicity upgraded from Category 4 (H332) to Category 3 (H331), with ATE value tightened to 3 mg/L (vapor)
- New oral acute toxicity Category 4 (H302), ATE of 500 mg/kg body weight
c) Retained Existing Classifications:
- Skin Corrosion Category 1A (H314)
- Aquatic Chronic Toxicity Category 3 (H412)
2. Other Approved Harmonized Classification and Labelling (CLH) Substances
|
Substance |
Main Classification Conclusions |
|
Bromuconazole |
Acute Toxicity Category 4 (H302), Carcinogenicity Category 2 (H351), Specific Target Organ Toxicity – Repeated Exposure Category 2 (H373, liver), Aquatic Acute/Chronic Category 1 |
|
l-carvone |
Skin Sensitization Category 1B (H317), Reproductive Toxicity Category 2 (H361d), Aquatic Chronic Toxicity Category 3 (H412) |
|
Spearmint oil |
Skin Sensitization Category 1B (H317), Reproductive Toxicity Category 2 (H361d), Aspiration Hazard Category 1 (H304); Aquatic chronic toxicity to be finalized at RAC-78 |
|
Fenazaquin |
Acute Toxicity Category 3 (oral H301) / Category 4 (inhalation H332), Aquatic Acute/Chronic Category 1 (M=100); Not classified for reproductive toxicity (sexual function and fertility) at this time |
|
Resorcinol |
New: Endocrine Disruptor – Human Health Category 1 (ED HH 1, EUH380) |
Note: The environmental endocrine disruptor classification for Propyl 4-hydroxybenzoate was withdrawn for further assessment; three morpholine compounds were fast-tracked via A-list (no plenary debate required).
3. Restriction Proposals
|
Substance |
Approved Opinion |
|
Octocrilene |
Recommended for restriction in finished cosmetic products; RAC reached consensus on persistence assessment, emission exposure, and alternative risks |
|
Hexavalent chromium compounds |
REACH restriction deemed appropriate as an EU-level measure in principle (assuming these substances are removed from REACH Annex XIV Authorization List); however, the current proposal was considered insufficient in effectiveness, practicality, and monitorability, with improvement recommendations provided |
ChemRadar Insights
Once the European Commission approves RAC's classification recommendations, TFA and its salts will be included in the harmonized classification list under Annex VI of the CLP Regulation. Enterprises should note:
- Labelling Obligations: All TFA products must bear GHS08 (Health Hazard), GHS06 (Skull), and GHS05 (Corrosion) pictograms, with the signal word "Danger"
- Safety Data Sheet (SDS) Updates: New hazard statements (H360Df, EUH450, EUH451, etc.) must be incorporated
- Downstream Communication Obligations: All supply chain stages must reassess risk management measures
- Potential Restriction Measures: PMT/vPvM classification may trigger further restriction assessments under the REACH Regulation
CIRS Group will continue to monitor the regulatory developments regarding TFA classification and provide enterprises with the latest compliance information.
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