For the first time, EU regulatory experts on chemicals have recommended the classification of two chemicals using the new hazard classes for endocrine disruptors and persistent chemicals, which were introduced in 2023.
Following discussions in the European Chemical Agency (ECHA)’s expert Risk Assessment Committee (RAC) last week, new opinions were adopted by consensus, based on scientific background documents, concluding that resorcinol should be classified as an endocrine disruptor for human health, and that trifluoroacetic acid (TFA) should be classified as Persistent, Mobile and Toxic (PMT), very Persistent very Mobile (vPvM) and also as toxic to reproduction. This outcome will now be sent to the European Commission for implementation into EU law.
The new hazard classes
The EU’s rules for classifying and labelling the hazards of substances (CLP) were updated in 2023 to add in the ability to identify chemicals with important additional hazards, and in these opinions RAC use three of them for the first time:
- Endocrine Disrupting Chemicals (EDC) – chemicals that disrupt the endocrine system of humans
- Persistent, Mobile and Toxic (PMT) – chemicals that stick around – and move around – in the environment, and are known to be toxic
- very Persistent, very Mobile (vPvM) – chemicals that stick around – and move around – in the environment to an even greater extent than PMT chemicals, but we don’t yet know they are toxic
Resorcinol recommended to be classified as an endocrine disruptor
The RAC committee recommended that resorcinol, a substance used in numerous applications including in cosmetics and hygiene products, should be classified as an endocrine disruptor (ED) for human health category 1. This is the first substance to be identified as an endocrine disruptor under the CLP regulation. CHEM Trust very much welcomes this important development, which is an important step towards better protecting people from EDs. We supported this classification in a submission to RAC in March 2025.
The substance had been identified as an endocrine disruptor by ECHA’s Member State Committee (MSC) in 2020, after the committee acknowledged that the substance meets the World Health Organisation’s definition. However, it was not identified as a Substance of Very High Concern (SVHC) under the REACH regulation, as the MSC did not reach an agreement on whether it met a separate criterion of being at ‘an equivalent level of concern’.
TFA recommended to be classified as PMT & vPvM, and as a reproductive toxicant
The RAC committee also recommended that TFA should be classified as as a reproductive toxicant category 1B, as Persistent, Mobile and Toxic (PMT), and very Persistent and very mobile (vPvM). TFA is the first substance to be classified as PMT or vPvM. We supported this classification in a submission to RAC in July 2025.
TFA is a particular important chemical, as it is a breakdown product of many per- and polyfluoroalkyl substances (PFAS), including certain pesticides, industrial greenhouse gases such as HFCs and HCFCs, and various other PFAS compounds. Monitoring has shown that TFA is contaminating the environment across Europe and worldwide, including in food and drinking water – for more details see our FAQ on TFA.
Next steps
The minutes of the meeting and the agreed opinions are available on the ECHA website.
Process for these new classifications becoming EU law:
- ECHA sends the RAC opinions to the European Commission, who will work with Member State experts to prepare a legal text for the classification and labelling of the substances concerned (actually an addition to annex VI of the EU’s Classification and Labelling regulation).
- The Commission will then notify EU Member States and the European Parliament of this legal text, and they then have a period for objection, once this is over then the legal text is published in the Official Journal and becomes law.
- Then all manufacturers, importers and downstream users of the substances in the EU must classify the substance in accordance with the updated classification.
Our view
Dr Ninja Reineke, Head of Science at CHEM Trust, said:
“We very much welcome RAC’s use of these new hazard classes – endocrine disruption, persistence and mobility are all important hazards for the environment and human health.
The decision will improve transparency on these substance properties for both businesses – including downstream users – and consumers.
The EU needs to move rapidly to put these new classifications into law, and regulators and companies in the EU and around the world should be taking action based on them now.
CHEM Trust particularly highlights the importance of rapid action to phase out all sources of TFA, to protect drinking water sources and minimize exposure.”
