The General Court of the European Union has upheld the European Chemicals Agency’s (ECHA) decision to list melamine as a Substance of Very High Concern (SVHC) under the REACH Regulation. The classification—proposed by Germany and unanimously supported by the Member State Committee (MSC)—was formally adopted by ECHA in December 2022. Issued on 9 July 2025, the ruling clarifies how combined intrinsic properties such as persistence, mobility, and long-range transport potential can justify SVHC status, with direct implications for the manufacturing and chemicals value chain.
SVHC Pathway
Germany submitted a dossier supporting melamine’s classification in August 2022, citing its probable serious effects on human health and the environment. Following consultation and unanimous endorsement by the MSC, ECHA confirmed the classification under Article 57(f) of REACH.
Melamine, widely used in resins, laminates, coatings, and adhesives, is now subject to enhanced regulatory scrutiny. Several affected businesses—among them LAT Nitrogen Piesteritz and Fritz Egger—challenged the decision in court, disputing both the scientific and procedural basis for the classification.
Court Validates Combined Property Assessment
The General Court dismissed these challenges, confirming that REACH allows ECHA to assess SVHC status based on the combined effects of multiple intrinsic properties, rather than requiring each to be independently severe. Properties like environmental persistence and mobility can be evaluated collectively when determining serious potential impacts.
The Court also clarified that REACH guarantees a public consultation rather than a formal hearing during the identification process. Stakeholders can submit comments, but are not entitled to procedural hearings.
Compliance and Risk Management Implications
This decision strengthens the legal and scientific framework for hazard-based regulation of chemicals in the EU. For manufacturers, importers, and downstream users, it underscores the importance of monitoring substance proposals, engaging early in public consultations, and preparing for potential authorisation or restriction measures.
Companies dealing with melamine must now consider supply chain communication, substitution, and potential reformulation to mitigate regulatory and reputational risks.
