PBT and PMT Substances
Substances that are Persistent, Bioaccumulative and Toxic (PBT) or Persistent, Mobile and Toxic (PMT). These hazard classes were introduced to the EU CLP Regulation to address chemicals that remain in the environment and accumulate in organisms or water supplies.
Foresight tracks PBT and PMT Substances developments and surfaces the alerts most likely to matter before they turn into missed deadlines, recalls, or escalation work.
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Last updated
13 May 2026, 11:52
Latest PBT and PMT Substances alerts
The most recent regulatory and guidance signals tracked by Foresight
ECHA Ends Consultation on Draft REACH Annex XIV Recommendation for Bumetrizole
On 2 May 2026, ECHA closed its public consultation on a draft REACH Annex XIV recommendation to add Bumetrizole (UV‑326) to the Authorisation List. This moves the substance one step closer to possible authorisation requirements under REACH, signalling likely future pressure for substitution or authorisation applications by affected users.
EU Parliament ENVI Committee Debates Objection to Approval of Pydiflumetofen as Candidate for Substitution
In May 2026, the European Parliament’s environment committee debated an objection to the European Commission’s draft implementing regulation that would approve the fungicide pydiflumetofen as a candidate for substitution under the EU plant protection products framework, drawing heavily on EFSA’s latest risk assessment. The exchange highlights growing political and regulatory sensitivity around highly persistent CMR-class pesticides and signals that future approvals may face stricter scrutiny on groundwater, drinking-water and data gaps, with potential knock-on effects for crop protection strategies and product portfolios.
EU Council Presidency Sets Out Omnibus X Compromise on Pesticide MRLs and Biocidal Products
The EU Council Presidency has issued a steering note on the Omnibus X food and feed safety package setting out compromise amendments to tighten pesticide MRL rules for non-approved hazardous substances and to shift most biocidal active substance approvals to unlimited duration. If agreed, these changes would move EU import standards closer to a zero-tolerance approach for high-risk pesticides while reshaping biocides approval and renewal strategies, raising future compliance stakes for agri-food exporters, pesticide manufacturers, and biocides companies.
EU Draft REACH Annex XVII Restriction on Terphenyl, Hydrogenated (PHT)
The European Commission is consulting on a draft REACH Annex XVII restriction that would ban most uses of terphenyl, hydrogenated (PHT) above 0.1% in substances, mixtures and articles, with WTO comments due by 7 July 2026 and adoption targeted for late 2026. If adopted broadly as proposed, the measure will force substitution away from PHT except in tightly controlled industrial heat-transfer systems and defence uses, with a long transition for civilian aerospace, so companies should map PHT uses, assess reliance on derogations, and plan alternative chemistries and product redesign.
Germany – Greens Propose Measures to Prevent PFAS ‘Forever Chemicals’ in Drinking Water
In May 2026 the Green Party in the German Bundestag tabled motion 21/5761 calling for aggressive measures to prevent PFAS “forever chemicals”, especially TFA, from contaminating drinking water and groundwater via pesticides, PFAS‑treated paper, fluorinated gases and industrial discharges. If taken up by the government this would tighten national PFAS controls, strengthen market surveillance and polluter‑pays liability, and reinforce German pressure for an EU‑wide PFAS group restriction and additional fluorinated gas limits under REACH.
ECHA Assessment of Regulatory Needs for 2,6-di-tert-butyl-p-cresol (BHT)
ECHA has issued a group Assessment of Regulatory Needs (ARN) for tert‑alkyl hindered phenols and created a dedicated ARN entry for 2,6‑di‑tert‑butyl‑p‑cresol (BHT), identifying it as part of a priority group with potential endocrine‑disrupting, reproductive and PBT/PMT concerns and widespread uses as an antioxidant in fuels, lubricants, plastics, coatings, adhesives and cosmetics. While no binding measure has yet been proposed, ECHA explicitly foresees harmonised classification followed by a REACH restriction if the hazards are confirmed, so companies using BHT at scale should monitor this file closely and consider substitution or risk‑reduction options in affected formulations and articles.
IIAR White Paper On Environmental And Health Risks Of Synthetic PFAS Refrigerants
IIAR has released a white paper warning that HFO and HFC/HFO PFAS refrigerants degrade almost completely into highly persistent trifluoroacetic acid (TFA), which is already widespread in US and European water but remains largely unregulated. For manufacturers and operators using synthetic refrigerants, the paper points to rising regulatory, liability and transition risks around PFAS-based F-gases and strengthens the case for accelerating shifts to natural refrigerants and closer tracking of future PFAS/TFA policy changes.
Germany Reports Rising Quantities of Second-Generation Anticoagulant Rodenticides
Germany’s federal government has published a 22 April 2026 reply revealing steadily rising notified quantities of second-generation anticoagulant rodenticide biocides between 2021 and 2025, while reiterating that these products are PBT, reproductive toxicants, and subject to strict authorisation and user-competence requirements. For pest control suppliers and agricultural users, this signals heightened regulatory scrutiny of high-risk rodenticides under the EU Biocidal Products Regulation and German law, reinforcing the need to maintain compliant quantity reporting, ensure trained professional users, and prepare for potential tighter EU restrictions on anticoagulant baiting.
Taiwan and Japan Adopt New POPs Restrictions on Methoxychlor, Dechlorane Plus, UV-328 and PFHxS
Taiwan and Japan have adopted new Stockholm Convention-aligned restrictions on methoxychlor, Dechlorane Plus, UV-328 and PFHxS-related substances under their national chemicals laws, with the measures entering into force in June and July 2026. These decisions will force manufacturers, importers and downstream users to phase out these POPs, tighten controls on mercury and tetrachloroethylene, and rapidly reassess formulations, supply chains and CSCL/TCCSCA compliance plans ahead of the upcoming deadlines.
EU ECHA Moves Melamine (108-78-1) CLH Proposal To Opinion Development Stage
Germany’s proposal to classify melamine as a suspected reproductive toxicant and PMT/vPvM substance under CLP has progressed to ECHA’s RAC opinion development stage following closure of the CLH public consultation in April 2026. If this proposal is adopted into Annex VI, EU companies using melamine in plastics, laminates, coatings and consumer goods will need to tighten classification, labelling and risk management, with particular attention to long-term water contamination and reproductive risk controls.
EU RAC Adopts vPvB CLH Opinion for N,N-Dicyclohexylbenzothiazole-2-Sulphenamide
In March 2026, the EU chemicals agency’s risk committee adopted its CLH opinion on N,N-dicyclohexylbenzothiazole-2-sulphenamide, supporting classification as very persistent and very bioaccumulative (vPvB) with supplementary hazard statement EUH441. This materially increases regulatory risk for this tyre and rubber accelerator under the EU CLP framework, signalling likely future Annex VI listing and the need to plan substitution and risk-management strategies across affected supply chains.
Northern Ireland: HSE Flags 1 June 2026 EU BPR Authorisation Deadline for Polymeric Betaine (PT 8)
EU approval of polymeric betaine as a biocidal active substance for wood preservatives takes legal effect on 1 June 2026, and HSE has warned Northern Ireland suppliers that EU BPR product authorisations must be in place by that date for PT 8 products containing this active. Companies with affected formulations should now confirm EU BPR authorisation coverage, plan around the substance’s candidate-for-substitution status and Annex risk controls, and align NI supply chains and treated wood labelling with the new approval conditions.
ECHA RAC Publishes vPvB/EUH441 CLH Opinion for 4,4'-Methylene Bis(dibutyldithiocarbamate)
ECHA’s Committee for Risk Assessment has adopted and, as of 25 March 2026, published its CLH opinion classifying 4,4'-methylene bis(dibutyldithiocarbamate) (CAS 10254-57-6) as a very persistent and very bioaccumulative substance with the supplemental hazard statement EUH441 under the EU CLP Regulation. Although no Annex VI adaptation has yet been proposed, this vPvB/EUH441 outcome is a strong signal of likely future binding harmonised classification, so EU manufacturers and downstream users should start assessing uses, exposure controls, and substitution options ahead of a potential ATP.
California DTSC Opens 15-Day Comment Period on Modified 1,4‑Dioxane Priority Product Listing for Manual Dish Detergents and Shampoo
In April 2026, California’s Department of Toxic Substances Control issued a 15-day notice of modified text under its Safer Consumer Products Regulations for listing manual dish detergents and shampoos containing more than 1 ppm of 1,4-dioxane as Priority Products. This is a late-stage refinement of the hazard justification rather than a scope change, but affected consumer and personal care brands should monitor closely and prepare for potential notification and alternatives analysis obligations once the listing is finalised.
PAN Europe Urges EU to Ban Diflufenican Over TFA Groundwater Risks
An EU NGO has issued an April 2026 call for the European Commission not to renew the herbicide diflufenican, arguing that it degrades into the ultra-persistent PFAS metabolite TFA which is already breaching groundwater limits and is now on the agenda of the 5–6 May EU pesticides committee meeting. This heightens near-term regulatory risk for diflufenican-based crop protection products and signals potential tightening of EU controls on TFA-forming PFAS pesticides and groundwater contaminants more broadly.
Portugal (APA) Reminder: CLP New Hazard Classes Mandatory for Mixtures From 1 May 2026
From 1 May 2026, new EU CLP hazard classes for endocrine disruptors and persistent chemicals become mandatory for new mixtures, with existing mixtures required to transition by 1 May 2028. Chemical manufacturers, importers and downstream users should now review mixture classifications, labels and safety data sheets across EU markets to ensure timely compliance and avoid last-minute relabelling or supply disruptions.
ECHA Assesses Regulatory Needs for Santicizer 278 (EC 701-008-3)
In March 2025 ECHA completed an assessment of regulatory needs for Santicizer 278 (EC 701-008-3) within a group of 2,2,4-trimethylpentanediol esters, flagging potential harmonised classification and future restriction under REACH and CLP. This non-binding screening signals that EU adhesives, coatings and related applications using this plasticiser may face tighter hazard classification and possible use restrictions, so companies should start reviewing data gaps, exposure controls and substitution options across affected portfolios.
EU Coreper Clears Council Decision on TBPH Submission to Stockholm Convention Annex A
In late March 2026, EU ambassadors (Coreper) cleared the Council Decision setting the Union’s position to request listing of TBPH in Annex A of the Stockholm Convention on Persistent Organic Pollutants. This signals that an EU-backed global phase-out proposal for TBPH is now in its final EU decision-making phase, increasing long-term substitution and POPs-compliance pressure for companies using the substance.
US Ninth Circuit Reply Brief Challenges EPA TSCA Fast-Track Exemptions for New PBT Chemicals
Environmental groups have filed a detailed reply brief in the US Ninth Circuit seeking to overturn EPA’s 2024 TSCA new-chemicals “fast-track” exemptions that let certain low-volume and low-exposure substances, including PBT and PFAS chemistries, bypass full premanufacture review. If the court agrees and partially vacates EPA’s fast-track provision, many new PBT and PFAS substances would instead face full TSCA PMN scrutiny, lengthening approval timelines and signalling that similar shortcuts in high-hazard chemical programmes are legally vulnerable.
ECHA Updates PBT Assessment List for Six Organic Substances
In April 2026, the European Chemicals Agency updated its PBT assessment list, recording a “not PBT / inconclusive” outcome for 2,4,6-triallyloxy-1,3,5-triazine and listing five additional organic substances – including 1,3-bis(isopropyl)naphthalene – as under development in the PBT review pipeline. These entries signal that authorities are actively screening these intermediates and dyes for potential PBT-type concerns under REACH and CLP, creating early warning for manufacturers and downstream users without yet imposing new binding restrictions.
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