ECHA Risk Assessment Committee Classifies Trifluoroacetic Acid (TFA) and Its Salts as PMT/vPvM Substances

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

CIRS 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.

About CIRS

Established in 2007, the CIRS Group is a leading product safety and regulatory consulting firm. CIRS has branch offices in the Republic of Ireland, South Korea, the United States, the United Kingdom, Japan, and China. CIRS Group utilizes its technical expertise, various resources, and international network to provide one-stop compliance services from regulatory compliance, laboratory testing, R&D to data services across multiple industries. This includes chemicals, cosmetics, food and food beverages, medical devices, agrochemical products, disinfectants, and consumer goods. It helps clients gain a competitive advantage by reducing business risks associated with regulatory affairs.

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