The Netherlands is set to refine its method for identifying potentially hazardous chemicals, or "Zeer Zorgwekkende Stoffen" (ZZS), by enhancing its early warning system with deeper integration of European substance assessments. The move, driven by the RIVM and Ministry of Infrastructure and Water Management (IenW), aims to improve risk awareness and strengthen regulatory oversight across the chemicals value chain.
The new approach centres on revising the pZZS list—the Dutch signalling list of substances that may pose serious risks to human health or the environment. This includes chemicals suspected to be carcinogenic, reprotoxic, persistent, bioaccumulative, or endocrine-disrupting. Since its inception in 2018, the pZZS list has served as a non-binding yet crucial reference for regulators and industry alike.
Under the revised methodology, the list will draw on a broader range of eleven European chemical registers, up from seven. These include data from REACH, CLP, the Stockholm Convention, OSPAR, and the Water Framework Directive, as well as lists for biocides, plant protection products, and food contact materials.
A key innovation is the categorisation of substances into “early warning” and “serious warning”. Early warning entries reflect substances under preliminary EU review, while serious warning entries are based on stronger evidence suggesting ZZS properties. This distinction gives regulators clearer insight into the likely regulatory trajectory of substances and enables industry to prepare accordingly .
REACH and CLP Among Primary Data Sources
The revised pZZS list will continue to rely heavily on REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) and the CLP Regulation (Classification, Labelling and Packaging). However, stricter criteria will now determine whether a substance is included. Substances classified solely via self-classification by companies (CMR 1A/B) will no longer be excluded, correcting a past gap where such substances were prematurely dropped from review despite ongoing EU investigations.
Additionally, the new framework includes substances assessed under recently introduced CLP hazard classes such as Persistent, Mobile and Toxic (PMT) and Endocrine Disruptors (ED), even though these are not yet formally recognised under REACH Article 57 criteria.
Implications for Permitting and Policy
For regulators and environmental permitting authorities, the enhanced signalling list is designed to streamline risk assessments and strengthen precautionary action during the licensing of industrial emissions. It supports the “minimisation obligation” embedded in Dutch ZZS policy, which requires companies to avoid or reduce emissions of ZZS wherever technically and economically feasible.
For industry, especially manufacturers and downstream users, this update signals a growing convergence between national precautionary policies and EU chemical safety systems. The improved transparency may lead to earlier identification of regulatory risks, market phase-outs, or substitution requirements.
The methodology was developed by RIVM and commissioned by the Ministry of Infrastructure and Water Management as part of its Impulsprogramma Chemische Stoffen, which runs until 2026.
