Highlights of ECHA's December Meeting: Progress on PFAS Restriction Proposal, vPvB Classification Forthcoming

The European Chemicals Agency's (ECHA) Committee for Risk Assessment (RAC) and Committee for Socio-economic Analysis (SEAC) made significant progress at their meeting on December 17, 2025. They held in-depth discussions on the assessment of the restriction proposal for per- and polyfluoroalkyl substances (PFAS) and, for the first time, issued a classification and labeling opinion for the new hazard category of "very persistent and very bioaccumulative" (vPvB) substances.

Progress on PFAS Restriction Assessment

RAC and SEAC have reached preliminary conclusions regarding the manufacturing stage of PFAS, with SEAC also formulating specific opinions on PFAS use in the electronics and semiconductor industries. The committees continued detailed discussions on cross-cutting issues within the restriction proposal, including:

The concentration threshold for PFAS restrictions;
Management plans and recycling schemes;
Exemption clauses for spare parts;
Enforceability and effective monitoring of measures;
Whether the proposed restrictions constitute the most appropriate risk management option at the EU level.

As planned, RAC is set to formally adopt its final opinion at the March 2026 meeting, while SEAC will finalize the draft and launch a 60-day public consultation to gather further feedback from stakeholders.

vPvB Classification

During the meeting, RAC adopted seven unified classification and labeling opinions, with the classification of 4,4'-methylenebis(dibutyldithiocarbamate) as vPvB standing out as a key highlight. This marks the first opinion issued by RAC for the new hazard category since the revision of the Classification, Labelling and Packaging (CLP) Regulation in 2023.

Classification and Labeling Opinions for Seven Substances

PBT or vPvB Properties

Classification criteria for PBT and vPvB substances

A mixture shall be classified respectively as a PBT or vPvB when at least one component contained in the mixture has been classified respectively as a PBT or vPvB and is present at or above 0.1 % (weight/weight).

Label elements for PBT and vPvB properties

	PBT	vPvB
Symbol/pictogram
Signal Word	Danger	Danger
Hazard Statement	EUH440: Accumulates in the environment and living organisms including humans	EUH441: Strongly accumulates in the environment and living organisms including humans
Precautionary Statement Prevention	P201 P202 P273	P201 P202 P273
Precautionary Statement Response	P391	P391
Precautionary Statement Storage	P501	P501

Safeguarding Future Health: Strictly Managing PFAS Risks

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Cosmetics (waterproof makeup, and personal care products); and

Plastic products and electronic device casings.

✅ High Precise Detection

CIRS Testing labs are equipped with a large number of advanced chemical analysis instruments such as LC-MS/MS, GC-MS/MS, with detection limits down to ppb levels. Our testing covers high-risk PFAS substances, including:

PFOA
PFOS
PFHxS
PFNA
PFBS

These methods ensure the scientific reliability of "non-detection" results.s.

✅ Customized Compliance Solutions

Our PFAS-free certification approach aligns with major international regulations and standards, including:

EU REACH Regulation (Annex XVII),
The US EPA PFAS Action Plan
China's Key New Pollutants Control List
Japan's Chemical Control Law

Find out more about the PFAS assessment process.

If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.

Further Information

ECHA

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