On March 21, 2024, the European RAC and SEAC agreed on numerous draft opinions concerning the use of hexavalent chromium, mainly in aerospace and defense, with formal adoption expected later. They also finalized decisions on chromium trioxide use in in hard chrome plating and functional chrome plating, emphasizing regulatory balance between health concerns and industrial applications.
Following requests from the European Commission, RAC revisited and unanimously reaffirmed its prior harmonized classifications for three lithium compounds—carbonate, chloride, and hydroxide—endorsing their designation as Reprotoxic 1A, indicating potential reproductive and developmental toxicity, and highlighting their probable adverse effects through lactation. Additionally, RAC concurred on categorizing methyl methacrylate (MMA) as a respiratory sensitizer, acknowledging its potential to provoke respiratory allergies and associated conditions upon inhalation.
During discussions on proposals to restrict perfluoroalkyl and polyfluoroalkyl substances (PFAS), RAC and SEAC considered the associated risks with PFAS, as well as the potential impacts of the proposal on ski waxes, cosmetics, and other consumer mixtures. RAC examined the hazards of PFAS, including the estimation of potential release volumes, while SEAC discussed the general approach to assessing different socio-economic factors related to the proposal. Furthermore, the committees will also discuss other topics at their meetings in June and September.
ChemRadar Insights
The most significant impact on Chinese enterprises from the recent RAC and SEAC meetings in March is undoubtedly the RAC's decision to maintain the classification of the mentioned three lithium salts as Category 1A reproductive toxicants. Once formally included in the CLP Harmonised Classification Catalogue, they will automatically enter the Restricted Substances List under Article 30 of the REACH regulation.
In adherence to EU directives on hazardous substances, suppliers must ensure their products are clearly labeled "For professional use only" before entering the market. With the ATP 21 classification list effective from September 2025, any amendments under ATP 22 will not be applicable until post-2026. Considering Restriction Article 30 predominantly affects consumer goods and lithium compounds are mainly industrial, businesses should now prioritize monitoring potential stringent EU regulations on lithium compounds and bolstering worker safety measures.
Substances classified as Category 1A or 1B reproductive toxicants in Part 3 of Annex VI to EU Regulation (EC) No 1272/2008 are listed in Appendices 5 and 6, respectively, with the following restrictions:
Without contravening other sections of this Annex, the provisions below apply to substances numbered 28 to 30, which must not be placed on the market or used:
As substances;
In mixtures.
They shall not be made available on the market, or used in substances or mixtures for sale to the general public, at individual concentrations equal to or greater than the specific concentrations set out:
In Part 3 of Annex VI to EU Regulation (EC) No 1272/2008;
In the specific concentrations specified by Directive 1999/45/EC.
