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- PFAS in Plant Protection Products: Latest Regulatory Developments and Perspectives
PFAS at the Heart of Regulatory Concerns Per- and polyfluoroalkyl substances (PFAS) are receiving increasing attention from European authorities due to their persistence, bioaccumulation, and toxicity. In this context, the Plant Protection Products (PPP) sector is now under closer scrutiny following the publication of the ECHA Annex XV restriction report . According to this report, active substances used in PPPs, biocidal products, and medicinal products differ chemically from other PFAS subgroups due to the presence of one or more CF₃ groups , a key molecular signature for understanding their environmental behavior . Key Figures from ECHA and the EU Pesticide Database While the PPP sector represents only 2% of total PFAS sales within the EU, it remains a major regulatory focus . Based on data from the European Pesticide Database , 89 molecules contain at least one CF₃ group: 57 have already expired and are no longer in use 1 is currently under evaluation for first approval 25 are undergoing renewal procedures 6 are scheduled for future renewal In addition, Annex A (v2 – 2023) lists 47 PFAS-based active substances used in PPPs (non-exhaustive list), all requiring further assessment and regular updates . Trifluoroacetic Acid (TFA): A Key Regulatory Issue Trifluoroacetic acid (TFA) can form in soil, water, and plants from the degradation of molecules containing CF₃ groups. Persistent and toxicologically relevant, TFA has now come under close examination by European authorities. Some active substances in PPPs degrade into TFA, potentially impacting renewal timelines or leading to stricter re-evaluations. What to Expect in 2025: EFSA Task Force Dedicated to TFA The European Food Safety Authority (EFSA) has established a dedicated working group to revise the toxicological reference values for TFA. Two initial meetings took place in November 2024 and February 2025, focusing on: Reviewing TFA data submitted by EU notifiers (in vivo and in vitro studies) Proposing updated reference values Coordinating with ECHA’s Risk Assessment Committee (RAC) and the German competent authority Additional meetings are planned throughout 2025, with an official EFSA statement expected by year-end, which could reshape evaluation and renewal strategies across the sector. CEHTRA’s Support CEHTRA’s experts assist companies in ensuring regulatory compliance regarding PFAS, helping them to: Interpret ECHA reports and data, Assess degradation pathways, including those leading to TFA, Anticipate regulatory impacts on their active substances and product portfolios Contact our Plant Protection expert, Estelle Beltran , for a tailored assessment and proactive strategy ahead of upcoming regulatory changes. Coming Next This article opens a dedicated series on PFAS regulatory developments in plant protection and biocidal products.With every EFSA/ECHA meeting or key regulatory milestone (2025–2026), CEHTRA will publish a concise and actionable update to help industry stakeholders stay informed and compliant.
- CEHTRA, Regulatory expertise driven by human and responsible values
At CEHTRA, we believe that scientific expertise alone is not enough. What truly makes a difference is the way it is put at the service of clients, teams… and, more broadly, society as a whole. Since day one, our teams have shared a strong conviction: no effective regulatory strategy can be built without a human, collaborative and responsible vision . Collective intelligence at the core of our support CEHTRA brings together an international and multidisciplinary team , fluent in English, French, German and Spanish , with professional backgrounds spanning industry, regulatory authorities, laboratories and consultancy . This diversity is our strength. It allows us to approach each dossier with a 360° perspective , anticipate regulatory developments and design strategies tailored to each market. “Working with different perspectives broadens our vision and pushes us to consider aspects we might not have identified on our own.” Client-focused support, from the first exchange to regulatory success At CEHTRA, one project means one dedicated point of contact . We believe in human, responsive and flexible support , where active listening is just as important as technical expertise.Our mission is not only to respond to regulatory obligations, it is to provide clear, actionable and reassuring solutions at every stage of the process . “Sharing our experience to build trust and co-develop effective strategies is what drives us every day.” Innovation and continuous improvement The regulatory landscape evolves quickly, very quickly . This is why we actively foster a culture of continuous improvement : new digital tools, optimized internal workflows, and open knowledge-sharing across teams and countries.At CEHTRA, innovation is not a statement, it is a daily practice serving our clients. A responsible and sustainable commitment Independent and part of the Social and Solidarity Economy (SSE) , CEHTRA operates with a strong environmental conscience.Our teams are 100% trained on climate impact awareness , and we actively work to reduce our carbon footprint by rethinking our ways of working, traveling and producing materials. More than a regulatory service provider, we aim to be a trusted partner committed to ethical and responsible collaboration . Choosing CEHTRA means choosing: Recognized scientific and regulatory expertise Human, tailored and attentive client support An engaged, multicultural and collaborative team A responsible vision of regulatory compliance, built for the future 📩 I nterested in discussing your regulatory challenges?
- CEHTRAWATCH: the smart digital regulatory monitoring tool for effortless compliance
In today’s fast-paced regulatory environment, staying ahead of changes in chemical and product regulations is more important than ever. Companies need a reliable, easy-to-use solution to track updates, ensure compliance, and mitigate risk. That’s where Cehtrawatch , our innovative digital regulatory monitoring tool , comes in. Streamline your regulatory compliance Cehtrawatch is designed to simplify compliance management. Whether you manage chemical substances, industrial products, or complex portfolios, our platform provides an intuitive interface that allows you to monitor regulatory changes in real time. With automated alerts and a comprehensive overview of all relevant updates, your team can focus on decision-making instead of manual tracking. Key features of CEHTRAWATCH - your digital regulatory monitoring tool Instant Portfolio Overview : Run a T0 scan of your substances in under 30 minutes, get a clear regulatory overview of your portfolio at a glance. Real-time regulatory alerts : Keep track of updates to regulatory and toxicological lists without constant manual checks. Change history tracking : Review updates over time to understand regulatory trends and prepare for upcoming requirements. User-friendly dashboard : Navigate complex regulatory data easily with a clean, intuitive interface. Customizable reporting : Generate reports tailored to your organization’s needs for internal tracking or regulatory submissions. Why choose CEHTRAWATCH? With the growing complexity of global regulations, relying on manual tracking or fragmented tools is no longer viable. Cehtrawatch empowers companies to: Reduce compliance risk and avoid potential fines Stay ahead of changes in regulatory and toxicological lists, with all updates carefully controlled by regulatory experts Save time with automated monitoring and reporting Make informed decisions backed by accurate, up-to-date regulatory data Ensure your business stays compliant effortlessly Access the platform instantly online — no installation or software required Get started today With CEHTRAWATCH, regulatory watch becomes simpler, faster, and more reliable. Whether you are in cosmetics, chemicals, pharmaceuticals, or other industries, this tool is designed to give you clarity and control. For more information or to schedule a demo of Cehtrawatch, please contact our key representative, Sara Lozano , who will be happy to guide you through the platform.
- n-Hexane: An Omnipresent Solvent, Soon to Be Classified as a “Substance of Very High Concern”?
n-Hexane (CAS No. 110-54-3) is a volatile aliphatic hydrocarbon derived from petroleum distillation. Used as a solvent, it plays a key role in several sectors: Food industry : extraction of vegetable oils (soy, rapeseed, sunflower), flavors, and proteins. Cosmetics and perfumery : obtaining absolutes, essential oils, and pure plant extracts. Its popularity is based on its efficiency, high yield, and low cost. However, this solvent requires strict purification to limit residues and protect exposed workers ( ANSES ). Long largely unknown to the general public, its use is now attracting attention. The press ( Le Point ) recently highlighted that it could indirectly be present in certain food products. Once metabolized, n-hexane is converted into 2,5-hexanedione, a molecule capable of accumulating in the brain and causing neurological effects ( Fiche toxicologique n°113 - Edition Juin 2025). The ECHA Proposal: Toward Inclusion on the SVHC List In February 2025, Slovenia proposed to ECHA (European Chemicals Agency) that n-hexane be classified as a Substance of Very High Concern (SVHC) due to its neurotoxicity. The public consultation, opened in August 2025, will close on October 16, 2025. This classification is based on Article 57(f) of the REACH Regulation (EC No. 1907/2006). The candidate SVHC list already includes over 240 concerning substances (carcinogens, reproductive toxins, endocrine disruptors, etc.). Inclusion triggers information obligations and can lead to authorizations or usage restrictions. Implications for the Cosmetic and Food Industries, and for Consumers Transparency and labeling: obligation to inform when a product contains more than 0.1%. Search for alternatives : adoption of safer processes (supercritical CO₂, “green” solvents). Costs and reformulations : adaptation of processes, investments, and potential increase in final product price. Health and public perception : better protection and transparency for consumers, but possible increased concern reported by media. Regulatory pressure and certifications : organic certifications and certain markets will likely require its absence, accelerating the transition to other techniques. This trend is already encouraging the development of solvent-free processes, such as the EcoXtract® approach. Consideration in Cosmetic Products In cosmetics, n-hexane may remain as trace residues after ingredient extraction. At these levels, the risks are considered negligible for consumers. European Cosmetic Regulation No. 1223/2009 requires safety assessors to check for these impurities in their reports. Classified as CMR (Repro cat.2, H361f) , n-hexane is prohibited as an ingredient in cosmetic products. As in the pharmaceutical sector (ICH Q3C (R8)), it is only tolerated as a residual impurity at strictly limited concentrations. Its neurotoxic effects, severe at high doses, are known and controlled through exposure thresholds. Therefore, the presence of traces does not pose a danger to the end user. Ensuring Safety and Anticipating Regulatory Changes For manufacturers, having a detailed toxicological profile of each substance is essential to secure formulations and anticipate regulatory developments. Potential inclusion of n-hexane on the SVHC list would mark an important step and could accelerate the transition to more sustainable alternatives. In the context of cosmetic regulations, having a detailed toxicological profile helps professionals anticipate and secure their formulations. ➡️ To explore the complete profile of this substance, visit our dedicated page: 👉 https://www.cehtra.com/cosmetick And check out the associated LinkedIn post for a concise overview.
- ECHA Issues New Restrictions on HOMONOPAL (Pinoacetaldehyde) – CAS 33885-51-7
A Floral Aldehyde Under Regulatory Scrutiny HOMONOPAL, also known as Pinoacetaldehyde, is a synthetic aromatic aldehyde commonly used in fragrance compositions. Its CAS number is 33885-51-7. Known for its green, floral, and slightly aldehydic scent, this compound imparts freshness and lift to perfume accords, particularly in fine fragrances, personal care products, and cleaning formulations. Industries Impacted HOMONOPAL is used across a wide range of sectors: Cosmetics and personal care, including perfumes, shampoos, lotions Household cleaning agents Industrial fragrance applications Its broad application stems from both its olfactory profile and its performance in complex fragrance matrices. New Regulatory Developments from ECHA In April 2025, the European Chemicals Agency (ECHA) published a new Assessment of Regulatory Needs (ARN) for Pinoacetaldehyde. This document significantly shifts the regulatory landscape for this fragrance ingredient, highlighting serious human health and environmental concerns. ECHA concludes the substance presents: Known or potential hazard for reproductive toxicity Known or potential hazard for skin sensitisation Known or potential hazard for aquatic toxicity Based on this assessment, ECHA outlines the following regulatory actions: "Harmonised classification as Reprotoxic category 1B." "Potential restriction: Harmonised classification as Repr. 1B would lead to generic restriction of the substance(s) in consumer mixtures by means of restriction entry 30." "The harmonised classification as Repr. 1B may trigger regulatory action under the Cosmetic Products Regulation and render the substance unacceptable as a co-formulant in biocidal products." The assessment also notes that HOMONOPAL is widely used in professional settings, often with low levels of operational controls and risk management: “Restriction of professional uses is preferred over authorisation as it is considered to be more efficient and effective to introduce controls at the level of placing on the market rather than at the level of uses.” "Frequent exposures with a long duration" are also highlighted, particularly concerning for vulnerable worker populations. Implications for the Cosmetics Industry The harmonised classification as Reprotoxic Category 1B has direct implications for cosmetic uses. Under the Cosmetic Products Regulation (EC) No 1223/2009, substances classified as Repr. 1B are generally prohibited unless explicitly exempted by the European Commission. In practical terms, this could mean: Prohibition of HOMONOPAL in consumer cosmetics Reformulation pressures on fragrance suppliers Loss of functionality in certain perfume accords If the restriction under Annex XVII, entry 30 of REACH is adopted, it will also mean a generic restriction in consumer mixtures, including many non-cosmetic fragrance applications. Conclusion The regulatory future of HOMONOPAL is now at a critical juncture. While still legally used today, the proposed harmonised classification and restrictions may lead to its complete phase-out in consumer products, including cosmetics. Formulators, regulatory teams, and risk assessors should begin preparing substitution strategies and consider the toxicological profile of alternatives. This case exemplifies the increasing scrutiny on fragrance ingredients and the importance of proactively managing substances with potential reproductive and environmental hazards. Link to the ECHA assessment
- Natural ingredients and food safety: myths, realities, and best practices
When it comes to nutrition, dietary supplements, or innovative ingredients, the word “ natural ” immediately inspires trust. But is a natural ingredient always safe for consumption? Spoiler alert : not necessarily. And this is precisely what scientists and food safety experts strive to demonstrate—with evidence to back it up. Natural does not mean harmless The misconception is persistent: what comes from nature cannot cause harm. Yet nature is full of active, powerful substances… sometimes toxic. Some well-known examples include: Certain plants, such as belladonna or foxglove, can cause severe poisoning. Essential oils, which are very popular, may contain molecules with neurotoxic or irritating effects that can present a risk if not used appropriately. Beyond the intrinsic composition of natural products, external contamination (heavy metals, hydrocarbons, bacterial toxins, microbes…) can also render natural substances unfit for consumption. In short: natural ≠ harmless. And this is something that national health authorities and EFSA (European Food Safety Authority) regularly remind us of through their scientific evaluation What determines the safety of a natural ingredient The safety assessment of an ingredient derived from natural products does not depend solely on its origin. It is based on several factors, including: Chemical composition : extraction, concentration, presence of secondary metabolites… Parts used : composition can vary greatly between a plant’s root, leaves, or fruit. Dose of exposure : “the dose makes the poison,” as Paracelsus once said. Mode of consumption : ingestion, skin application, inhalation… Consumer profile : healthy adult? pregnant woman? child? A plant extract used for centuries in herbal tea can become problematic if concentrated in a dietary supplement or given to a vulnerable population. An essential safety evaluation In Europe, food ingredients without a significant history of consumption prior to 15 May 1997 are considered Novel Food . This means they must undergo an authorization request to the European Commission. The aim of this request is to demonstrate the safety of the Novel Food under the intended conditions of use. These often complex dossiers must provide scientific evidence, frequently supported by toxicological data, of their safety. Even outside the Novel Food framework, all food products, including those already authorized, must be free of risk for consumers. It is the responsibility of manufacturers and/or market operators to ensure this absence of risk, by keeping up to date with regulatory and toxicological developments concerning the ingredients they use. CEHTRA supports you in securing your natural ingredients At CEHTRA, we support industries, start-ups, and project leaders through these complex steps of assessing the safety of their products. We offer: Analysis of available toxicological data on your product ingredients Identification of regulatory status (Novel Food or not) Preparation of a solid safety dossier Integration of digital tools to anticipate potential issues Our specialized team helps you secure innovation without slowing down your ambitions. The goal? To launch your ingredient in full compliance, with a clear, transparent, and reassuring message for your clients and partners. Contact Marie Liamin , Food Products Market Leader, or visit the dedicated page for more information.
- Glabridine: An Ingredient Under Scrutiny in Cosmetics
1. Known Uses Glabridine is an isoflavonoid (isoflavane) extracted from Glycyrrhiza glabra (licorice root). It is widely used in cosmetics for its skin-lightening and anti-tyrosinase activity, as well as for its antioxidant and anti-inflammatory properties. It is mainly found in skincare products, anti-aging creams, and sunscreens. 📖 J Lui, 2025 ScienceDirect 2. Mechanism of Action of Glabridine Glabridine inhibits tyrosinase, a key enzyme in melanin synthesis responsible for skin pigmentation. It acts as a reversible, non-competitive inhibitor, meaning it effectively reduces tyrosinase activity without directly binding to its active site. This inhibition occurs through a multi-phase kinetic process, suggesting the formation of a stable glabridine-tyrosinase complex. 📖 J Chen, 2016 PubMed 3. Toxicological and Regulatory Concerns Available scientific data show efficacy in tyrosinase inhibition, but systemic toxicity studies remain limited. Points of caution include: The potential estrogenic activity of certain isoflavones, an endocrine-disrupting effect observed in some tests, particularly in vitro, cannot be excluded (CIR Glycyrrhiza Glabra (Licorice), 2008) CIR Reports Limited data on systemic toxicity and reproductive toxicity (EFSA, 2011) EFSA Journal Our view: Such effects and “data gaps” warrant further research. In the context of cosmetic regulations, having a detailed toxicological profile helps professionals anticipate and secure their formulations. To explore the complete profile of glabridine, visit our dedicated page: https://www.cehtra.com/cosmetick 📢 And check out the associated LinkedIn post for a concise overview : https://lnkd.in/p/eSj7GxE5
- Disinfectants and Biocides: Application Frequency Must Be Specified – New Rules from CG-54
In the recent meeting of Coordination Group (CG-54), a proposal of the Austrian Member State was discussed which has been raised in a CG e-consultation, concerning information on the use frequency of products (“Number and timing of application”) for use in PT 1, PT2 and PT4 given by the applicants in SPC and PAR for BPR product authorization. Austrian authorities are experiencing that applicants often use quite general terms for application frequency for professional and nonprofessional use, such as “as required” or “daily use”, etc. It has been proposed that these general terms must not be accepted any longer by the Member States, as the application frequency, e.g., expressed in number of applications per day, determines how often the product is applied and is a crucial input parameter especially for human exposure assessment. The maximum or typical number of applications per day must be stated in SPC and DRA/PAR authorised use to reflect realistic worst-case assumptions. This proposal has been agreed at CG-54 meeting in November 2022 by consensus: For product authorisation, the use frequency must be given in SPC and PAR according to the guidance and Annex VI, point (33) of the BPR and the term ‘as required’ (or similar terms, e.g. ‘daily use’) for determination of application frequency shall be no more accepted by the member states for the application frequency without further justification. Details of application frequency are relevant input parameters for human and environmental exposure and risk assessment. Therefore, the (maximum or typical) number of applications per day must be stated in SPC and DRA/PAR authorised use. Examples are given as follows: Example 1 , hand disinfectants used in the medical sector: Nurses or hospital/medical staff should use hand disinfectants as often as necessary. However, in the case of hand disinfectants, a “maximal or typical” number of applications per day should be indicated in SPC and PAR authorised uses. This number should correspond to the safe number of applications determined by the exposure scenario (reverse reference scenario). Example 2 , surface disinfection products: no clear use frequency can be set. Therefore, a “maximal or typical” number of applications per day should be indicated in SPC and PAR authorised uses. This number should correspond to the safe number of applications determined by the exposure scenario ( reverse reference scenario , chapter 3.2.5.5). Example 3 , automated dosing: In certain situations, “as required” can mean “adding the product intermittently to the system, in order to maintain a system concentration within certain defined limits”. In such cases, the term “as required” might be acceptable. However, typical and/or maximal amount of product needed for application should be given. This conclusion might generally be applied to all PTs. Sources: CG-54_e-c Use of the term as required for the application frequency_vf.pdf ECHA Guidance on the Biocidal Products Regulation Volume III Human Health - Assessment & Evaluation (Parts B+C), Version 4.0, December 2017, chapter 3.2.5.5 Reverse reference scenarios
- ADBAC/BKC in PT2 - Information on Approval Status
On 2nd of December 2021, the ECHA Biocidal Products Committee (BPC) recommended the approval of ABDAC/BKC and adopted the BPC opinion for PT2 by simple majority. Two Member States (Germany and Finland) raised their concerns about unacceptable risk for environment, mainly for the soil compartment. As the concerns could not be solved at the 76th meeting of the Standing Committee of Biocidal products (SCBP) on 24th June 2022, ECHA organized a dedicated meeting with the eCA, the concerned Member States and the Commission services on 23rd August 2022 to resolve the reservations of the concerned Member States. It became clear during the 77th meeting of the SCBP that further discussions and assessment are needed to be able to clarify whether the exposure of the active substance to soil compartment is resulting in an acceptable risk or not. Therefore, ECHA is requested to revise its opinion on ADBAC/BKC for PT2 considering the information available in the application for approval of the active substance, discussions and arguments expressed during the various expert and regulatory meetings (BPC Environment Working Group, BPC plenary, the Standing Committee meeting, and the ad-hoc meeting of 23 August 2022), as well as the additional arguments that may be put forward during the additional discussions it will organise. ECHA is requested to provide a revised assessment report and a revised opinion. As the opinion shall be adopted by 30th June 2023 at the latest, the approval of ADBAC/BKC for PT2 can be expected in July 2025. Sources: Mandate requesting ECHA opinions under Article 75(1)(g) of the BPR "Re-assessing the risk on the environment (soil compartment) posed by ADBAC/BKC from use in biocidal products of PT2"
- Framework Guidance: Analysis of alternatives tobiocidal active substances
ECHA developed in 2022 a recommended (i.e. not mandatory) framework guidance to applicants for approval of biocidal active substances but also to Member State Competent Authorities (MSCAs) on how to perform an analysis of alternatives (AoA) to active substances being candidate for substitution (CfS) according to Art. 10(1) of the Biocidal Products Regulation ((EU) 528/2012). The guidance has been adopted at BPC-45 meeting and published in January 2023. It provides a set of elements which can be used to assess the availability of suitable alternatives to substances meeting the exclusion criteria (Art.5(1)), and substances meeting the substitution criteria (Art. 10(1)), but not the exclusion criteria. It allows a flexible approach, tailored to the case and the entity performing the analysis of alternatives (i.e. an applicant or a MSCA). Applicants for CfS are advised to submit analysis of alternatives to MSCAs which are as comprehensive as possible, including a public version for publication, covering the different intended uses as part of their application. The submission of an AoA is not legally required but strongly recommended to support the comparative assessment at product authorisation stage as products containing a candidate for substitution will have to be subject to a comparative assessment by the receiving/evaluating competent authority at the time of authorisation and will only be authorised if there are no suitable alternatives (Art. 23(3)). Evaluating MSCAs also do not have a legal requirement to make an AoA per se in the active substance approval/renewal process but might be willing to make one themselves, e.g. as a complement to one submitted by an applicant. An analysis of alternatives is recognized to be very challenging due to numerous limiting factors such as limited and variable information on intended uses of biocidal products containing this active, limited information on number of uses, biocidal products and treated articles on the EU market, limited knowledge and expertise on the uses and potential active substance alternatives. Furthermore, approval of active substances according to different requirements and rules, different dossier types at different stages of the regulatory process also lead to uncertainties in the assessment of chemical alternatives. Despite these limitations, such analyses conducted by the applicants for CfS can provide a useful set of information for either the substance approval/renewal or for subsequent product comparative assessment. A good quality and sufficiently detailed analysis of alternatives provided by the applicant could lighten the workload for the more specific comparative assessments at product authorization stage. The information on alternatives collected at the stage of active substance approval/renewal can also be used by third parties willing to submit information on alternatives during the third parties’ consultations under Article 10(3). This guidance is mainly addressed to: The applicants to support their application for approval/renewal of a biocidal active substance which is meeting the exclusion or substitution criteria The MSCAs willing to perform an analysis of alternatives for active substances meeting the exclusion or substitution criteria (as a complement to one submitted by an applicant or for other reasons) It should be seen as a recommended non-mandatory framework guideline, providing advice on how to perform and structure an analysis of alternatives for active substances candidate for substitution. It is accompanied by a template which provides a structure for reporting this analysis. Applicants of such substances are advised to use this guidance and to submit an analysis of alternatives to their eCA as part of their application. A public version of this analysis is intended to be published on ECHA’s website. The guidance does not lead to clear-cut conclusions on the availability of suitable alternatives for the intended uses. This first version describes the desired content for AoA but not the content for the related aspects of the derogation criteria related to Art 5(2)(b)5 or Art 5(2)(c)6. For the latter criteria, the ECHA guidance on socioeconomic analysis may be mainly considered. Sources: Analysis of alternatives to biocidal active substances for applicants and authorities: a recommended framework guidance CA-Dec22 Doc.5.4.a AoA Guidance implementation Final.docx Template for analysis of alternatives ECHA guidance on socio-economic analysis
- REACH Chrome (VI): Towards a European Restriction to Protect Health and the Environment
The European Chemicals Agency (ECHA) has recently published a proposed restriction targeting several hexavalent chromium (Cr(VI)) substances , classified as proven carcinogens , to strengthen the protection of workers and communities near industrial sites. Transition from REACH Authorization to Restriction Main objective: Replace the current REACH authorization regime with a faster, clearer, and more effective restriction to better control the use of Chromium(VI) . The proposed restriction would apply to the following uses: Formulation of mixtures containing Chromium(VI) Electrodeposition on plastic substrates Electrodeposition on metallic substrates Use in primers and sludges Other surface treatment processes Functional additives or process auxiliaries ⚠️ These uses would only be allowed if occupational exposure limits and environmental emission limits are respected.All other uses would be prohibited. Public Consultation: A Crucial Opportunity A 6-month public consultation will start on June 18, 2025 . This is a key step for industrial users , allowing companies to voice their opinions and defend their uses by providing technical, scientific, or socio-economic data . Need Assistance? Our team, Stéphane Pierre and Alexia Contin , can support you with risk assessment, regulatory strategy, and participation in the consultation process .
- PPWR: A New Era for Sustainable Packaging Management in Europe
With the recent publication of the Packaging and Packaging Waste Regulation (PPWR) , Europe is entering a new chapter in circular packaging management , strengthening its commitment to sustainability and the reduction of plastic waste . This regulation introduces key principles that will reshape the packaging industry: Recyclability of Packaging The PPWR requires packaging to be fully recyclable, meaning that all materials must be efficiently processed and reused. This is a major step toward a more circular and sustainable economy. Mandatory Recycled Content The regulation sets a minimum percentage of recycled content for plastic packaging from post-consumer waste. This encourages the use of recycled materials, reduces reliance on virgin resources, and boosts the recycling market. Waste Minimization PPWR aims to reduce packaging waste by promoting efficient, lightweight designs that use fewer materials while maintaining functionality. Harmonized Labeling and Sorting The regulation introduces Europe-wide harmonization of packaging labeling and sorting instructions. This makes it easier for consumers to sort packaging waste and allows businesses to comply with consistent guidelines, improving overall waste management. CEHTRA: Your Partner for PPWR Compliance At CEHTRA, we support companies in adapting to these new requirements. Our expertise helps you stay compliant with regulations while implementing sustainable and circular packaging solutions. Ready to ensure your packaging is fully compliant? Contact us today to get expert guidance from CEHTRA.
- Annex VIII to CLP Regulation: Understanding Your Obligations for Poison Centre Notifications (PCN)
In March 2017, Annex VIII to the CLP Regulation was introduced to harmonise the poison centre notification (PCN) process across EU Member States. This harmonised system became fully effective in January 2021 (extended from January 2020). Who is concerned? All importers and downstream users placing hazardous mixtures (classified for health and/or physical effects) on the EU market must provide specific information about their mixtures to the centralised EU poison centre before placing them on the market. Key obligations To comply with Annex VIII, companies must: Register a Unique Formula Identifier (UFI) Include the UFI on the label for consumer and professional use Include the UFI in Section 1.1 of the Safety Data Sheet (SDS) for industrial use They must also submit a notification via the ECHA harmonised submission portal , including: The full chemical composition of the mixture Toxicological information (SDS Section 11) The product category (according to the EU Product Categorisation System – EUPCS) The SDS and label in the national language of the country where the product is placed on the market The UFI , a 16-character alphanumeric code that uniquely identifies the mixture and can be generated using ECHA’s UFI Generator Who holds the obligation? The obligation lies with the EU legal entity (importer or downstream user).A non-EU supplier cannot fulfil this requirement on behalf of the EU-based duty holder.However, a duty holder can entrust a third party , such as CEHTRA , to prepare and submit the PCN notification on their behalf. Compliance timeline Depending on the use of the mixture, the following deadlines apply: Hazardous mixtures for consumer and professional use: from 1 January 2021 Hazardous mixtures for industrial use: from 1 January 2024 Existing mixtures already notified under national systems: by 1 January 2025 How CEHTRA can support your PCN compliance CEHTRA provides a full range of regulatory support services to help you ensure compliance with Annex VIII requirements: Portfolio Review Screen your portfolio to identify mixtures that require PCN and determine notification deadlines. Safety Data Sheet and Label Review Perform a full compliance review of SDSs and labels to ensure they meet CLP and Annex VIII requirements. PCN Preparation and Submission Prepare and submit PCN notifications via the ECHA submission portal. UFI Generation Screen for full notification information and generate UFI codes for each mixture. Regulatory Advice Offer tailored regulatory advice on how best to fulfil your obligations under the CLP Regulation. With CEHTRA’s expertise, you can achieve and maintain full compliance with EU poison centre notification requirements efficiently and confidently.













