Chemicals | Monthly bulletin | May 2025

New requirements for PFOS and its derivates
On the 14th April 2025, the European Commission adopted the delegated Regulation, which amends Annex I to Regulation (EU) 2019/1021 as regards perfluorooctane sulfonic acid (PFOS) and its derivatives. The main changes are:
- The same terminology is used as in the PFOA entry. This way the two definitions are aligned.
- There are new limits to substances, mixtures or articles:
- PFOS or any of its salts ≤ 0,025 mg/kg (0.0000025 % by weight)
- The sum of concentrations of all PFOS-related compounds ≤ 1 mg/kg (0.0001 % by weight).
- Removal of the exemptions for the use of PFOS as mist suppressant for non-decorative hard chromium (VI) plating and references to the availability of analytical methods
It is pending publication in the Official Journal of the European Union soon.
For more information, consult the public consultation in European commission website here.
Recent publications on REACH Regulation
The following table provides a non-exhaustive summary of some recent updates regarding REACH Regulation (EC) No 1907/2006:
Summary of the most recent updates |
||
Date |
Subject |
Link |
19/03/2025 |
In their first meetings of 2025, The Committees for Risk Assessment (RAC) and Socio-Economic Analysis (SEAC) continued evaluating the EU-wide proposal to restrict per- and polyfluoroalkyl substances (PFAS). Both committees reached provisional conclusions for applications of fluorinated gases. |
For more information, consult the ECHA’s website here. |
26/03/2025 |
The European Chemicals Agency (ECHA) updated the list of substances and product-type combinations that can be used in treated articles. |
For more information, consult the ECHA’s website here. |
27/03/2025 |
In the latest Enforcement Forum meeting, it was agreed that in the REF-14, inspectors will focus on checking mixtures as nicotine products that may contain acutely toxic substances or products containing scented mixtures, such as air fresheners known to contain irritant substances. The controls will also include new requirements for the Classification, Labelling and Packaging (CLP), such as fold-out labels, digital labelling or supply of mixtures at refill stations. |
For more information, consult the ECHA’s website here. |
01/04/2025 |
The European Commission published an Explanatory Guide to help with the implementation of the microplastics restriction under REACH legislation. The guide includes a section describing the provisions, objectives of the restriction, questions and answers, annexes with ‘decision trees’, and examples of borderline cases. |
For more information, consult the official publication in the European’s Website here. |
02/04/2025 |
The European Commission published Commission Regulation (EU) 2025/660 of 1 April 2025, amending Annex XVII to Regulation (EC) No 1907/2006 of the European Parliament and of the Council as regards polycyclic aromatic hydrocarbons (PAHs) in clay targets. |
For more information, consult the official publication in the European’s Website here. |
16/04/2025 |
ECHA's 2024 Annual Report was published. It provides a comprehensive account of the activities carried out by ECHA during 2024, the performance of the Agency against the expected inputs, outputs and outcomes defined in the Single Programming Document 2024-2026. It also represents a fair overview of the evolution of ECHA’s budget, staffing, management, and its internal management system strategy and framework. |
For more information, consult the ECHA’s website here. |
16/04/2025 |
ECHA have published the definition of the information that will be required to fulfil the microplastics annual reporting obligations according to EU’s restriction on intentional uses of microplastics |
For more information, consult the ECHA’s website here. |
11/04/2025 |
ECHA published the restricting the use of certain chromium (VI) substances dossier. The Commission is therefore requesting ECHA to prepare a restriction dossier in line with the requirements of Annex XV. |
For more information, consult the ECHA’s website here. |
03/04/2025 |
On the 1st of May 2025, the public consultation related to chemical regulation - update of EU rules for test methods. This initiative will add a number of new/updated methods to that list, which have the potential to reduce or refine the amount of animal testing using chemicals. Adoption by the Commission is planned for the third quarter of 2025. |
For more information, consult the official publication in the European initiatives here. |
09/04/2025 |
The European Commission published the draft amending Regulation (EC) No 440/2008 as regards the test methods, to adapt them in line with technical progress. The Regulation (EC) No 440/2008 lays down test methods pursuant to Regulation (EC) No 1907/2006 of the European Parliament and of the Council on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH). |
For more information, consult the official publication in the European’s Website here. |
Interesting resources on REACH Regulation on the ECHA’s website
- Registry of restriction intentions until outcome - ECHA (europa.eu)
- Registry of SVHC intentions until outcome - ECHA (europa.eu)
- Substance evaluation - CoRAP - ECHA (europa.eu)
- Adopted opinions and previous consultations on applications for authorisation - ECHA (europa.eu)
- Applications for authorisation - current consultations - ECHA (europa.eu)
- Current calls for comments and evidence - ECHA (europa.eu)
- Authorisation List - ECHA (europa.eu)
- ECHA's completed activities on restriction
- Submitted restrictions under consideration
- Assessment of regulatory needs list
Interesting resources on the CLP Regulation on the ECHA’s website
- Registry of CLH intentions until outcome - ECHA (europa.eu)
- Harmonised classification and labelling consultations - ECHA (europa.eu)
New persistent organic pollutant substances in UK
On 11th March 2025, the UK POPs Regulation was amended by the Persistent Organic Pollutants (Amendment) Regulations 2025 (S.I. 2025/296) and The Persistent Organic Pollutants (Amendment) (No. 2) Regulations 2025 (S.I. 2025/297). These regulations amend provisions in Annex 1 to the UK POPs Regulation as follows:
- Adding Dechlorane Plus and UV-328
- Adding Methoxychlor (already included in EU POP Regulation and aligned with it)
- Amending the entries for Hexachlorobenzene, Pentachlorophenol and Perfluorooctanoic acid (aligned with EU POP Regulation)
This follows the decision made at the eleventh meeting of the Conference of the Parties to the Stockholm Convention in May 2023, where Dechlorane Plus and UV-328 were added in Annex A to the Convention with certain specific exemptions.
The amendments entered into force on 1 April 2025.
The requirements for Dechlorane Plus and UV-328 under UK POP Regulation are as follows:
Substance |
UK requirements under Annex I of UK POP Regulation (*) |
Some common uses |
UV-328 2-(2H-benzotriazol-2-yl)-4,6-ditertpentylphenol CAS No 25973-55-1 EC No 247-384-8 |
≤ 10 mg/kg (0.001% by weight) in substances, mixtures or articles. |
UV absorber used in paints, coatings, sealants, printing inks, adhesives, resigns, plastics, and vehicles. |
Dechlorane plus includes its syn-isomer and anti-isomer CAS No 13560-89-9 135821-03-3 135821-74-8 EC No 236-948-9 |
≤ 10 mg/kg (0.001% by weight) in substances, mixtures or articles. |
Polychlorinated flame retardant used in plastic products, textiles, adhesives, cables, motor vehicles, medical devices, E&E equipment, electronic devices, machinery, aerospace and defense. |
(*) Allowed uses/exemptions not included in this table.
As of now, Dechlorane Plus and UV-328 are not included in EU POP Regulation yet. In the EU, the European Commission held public consultations on these substances on whether to add them in Annex I of Regulation (EU) 2019/1021. The public consultations are closed and it is expected that the Commission will adopt them soon.
Updates in the Swiss chemical legislations
On the 14th of April 2025, the Swiss Federal Office of Public Health (BAG) notified the World Trade Organization of the following amendments to the Swiss Chemical Ordinances. In this way, the Swiss chemical legislation and the European legislation have more similar requirements. The notifications are:
Reference |
Title |
Description |
Adaptation Annex 1.10 of Chemical Risk Reduction Ordinance (ORRChem) |
In Annex 1.10 ChemRRV: 16 additional substances are included by reference to the EU regulations. These substances may no longer be supplied to the general public after August 31, 2025. |
|
Adapation of Annexes 2 and 3 of the Ordinance on Protection against Dangerous Substances and Preparations (Chemicals Ordinance; ChemO) |
Harmonized classifications and labelling of substances
|
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 |
European Commission |
31/03/2025 |
Commission Implementing Regulation (EU) 2025/623 of 28 March 2025 establishing, pursuant to Regulation (EU) 2024/573 of the European Parliament and of the Council, minimum requirements for certificates of natural persons and the conditions for the mutual recognition of such certificates as regards the recovery of fluorinated greenhouse gas-based solvents from equipment and repealing Commission Regulation (EC) No 306/2008. |
European Commission |
31/03/2025 |
Commission Implementing Regulation (EU) 2025/625 of 28 March 2025 establishing, pursuant to Regulation (EU) 2024/573 of the European Parliament and of the Council, minimum requirements for certificates of natural and legal persons and the conditions for the mutual recognition of such certificates as regards stationary fire protection equipment containing certain fluorinated greenhouse gases or relevant alternatives and repealing Commission Regulation (EC) No 304/2008. |
European Commission |
31/03/2025 |
Commission Implementing Regulation (EU) 2025/627 of 28 March 2025 establishing, pursuant to Regulation (EU) 2024/573 of the European Parliament and of the Council, minimum requirements for certificates of natural persons and the conditions for the mutual recognition of such certificates, as regards the installation, maintenance or servicing, repair or decommissioning of stationary electrical switchgear containing fluorinated greenhouse gases and recovery of fluorinated greenhouse gases from stationary electrical switchgear and repealing Commission Implementing Regulation (EU) 2015/2066. |
European Commission |
14/03/2025 |
Commission's Action Plan to secure a competitive and decarbonised steel and metals industry in Europe. |
European Commission |
26/02/2025 |
A Clean Industrial Deal for competitiveness and decarbonisation in the EU. |
European Commission |
19/02/2025 |
The European Commission organised the first high-level meeting of the Net-Zero Europe Platform, marking the formal launch of the platform. For more information, consult the Net-Zero Europe Platform webpage. |
UK Ministry of Foreign Affairs |
06/04/2025 |