CLP Annex VI update: EU proposes major transfer of SVHC and hazardous substances

Key substances in the CLP Annex VI update

The proposal includes widely used industrial chemicals such as siloxanes (D4, D5, D6), polycyclic aromatic hydrocarbons (PAHs) like anthracene and pyrene, and flame retardants including decaBDE and HBCDD. Several UV stabilisers (for example UV-328, UV-327) and per- and polyfluoroalkyl substances (PFAS), such as PFHxS and related acids, are also listed. Many entries are classified as PBT or vPvB, triggering environmental hazard statements EUH440 and EUH441. Others, including bisphenol B and certain phenolic substances, are identified as endocrine disruptors for human health or the environment, carrying EUH380 or EUH430 classifications.

Endocrine disruptors and PFAS in focus

The inclusion of endocrine-disrupting chemicals reflects increasing regulatory scrutiny. Substances such as bisphenol analogues and alkylphenols are widely used in plastics, coatings and resins, meaning their reclassification could have far-reaching supply chain implications. PFAS entries highlight ongoing EU efforts to address persistent pollutants. These substances are valued for water and heat resistance but are linked to long-term environmental accumulation and health risks.

Implications for industry and compliance

For manufacturers and importers, the CLP Annex VI update will require revised classification, labelling and packaging. Safety data sheets must be updated, and mixtures may require reclassification where concentration thresholds are exceeded. Downstream users, including formulators and product designers, will need to reassess raw material choices. Sectors such as electronics, automotive, construction and consumer goods could face reformulation pressures, particularly where siloxanes, flame retardants or UV stabilisers are used. Regulatory teams should also note mixture classification rules. The document specifies that mixtures must be classified as PBT or vPvB when relevant substances exceed 0.1% concentration thresholds.

Alignment across EU chemicals legislation

A key objective is alignment between REACH, CLP and sector-specific regulations. By transferring SVHC classifications into CLP Annex VI, authorities aim to ensure consistent hazard communication across all uses, reducing regulatory fragmentation.

What companies should do next

Organisations should begin gap assessments against the proposed classifications, prioritise high-risk substances and engage with suppliers. Early action can reduce disruption and support substitution strategies. Call to action: Review your portfolio for listed substances and initiate compliance planning ahead of formal adoption to avoid supply chain delays.