Regulatory News - September 2026

^{Stano Gajdoš}

September was a POPs month. Chlorpyrifos went onto the EU’s POPs list on the month’s last day, medium-chain chlorinated paraffins and long-chain PFCAs follow in December, and Serbia is working through recent Stockholm Convention listings on its own timetable. CLP did the quieter and arguably more consequential work: the first endocrine-disruptor opinions, one for human health and one for the environment, are now in, only weeks before self-classification against the new hazard classes is due, and distributors have a clearly defined role in PCN from January 2027. Underneath all of this is an older pattern: the substances that replaced the problem chemicals of the past are becoming problems of their own. And Great Britain finally put its ATRm into draft legal text.

1. A POPs month

Commission Delegated Regulation (EU) 2026/1423 added chlorpyrifos to Part A of Annex I of the POPs Regulation, with effect from 30 September. The EU took no specific exemptions under the Stockholm Convention listing it implements, so the prohibition covers the substance on its own, in mixtures and in articles. The only allowance is an unintentional trace contaminant limit of 0.01 mg/kg.

It might be tempting to wave this one through, as chlorpyrifos is not approved as an active substance in plant protection products or biocidal products in the EU. So who still has it? Possibly your imports. The POPs listing reaches plant-derived raw materials, wood packaging and recycled content from markets where chlorpyrifos is still in use, and residues can persist in all of them.

Two more listings are queued. Delegated regulations adopted on 11 and 7 September, respectively, add medium-chain chlorinated paraffins (C14–C17) and C9–C21 perfluorocarboxylic acids, their salts and related compounds to Annex I. Both are set to apply from 16 December 2026, once the Parliament and Council scrutiny period ends. MCCPs carry a 0.1 % w/w trace-contaminant limit and time-limited exemptions: construction cables and door and window sealants until 2028, medical-device cables until 2031, heavy-duty metalworking fluids until 2036, and spare parts until 2041. There is a new SDS duty attached. Suppliers of chlorinated paraffins must state MCCP content and, above 0.1 %, the measures taken to minimise release and exposure. On the PFCA side, the Commission has committed to starting the removal of REACH Annex XVII entry 68 (C9–C14 PFCAs), as it did for PFOA.

Great Britain is following. Defra’s draft Persistent Organic Pollutants (Amendment) Regulations 2026 would add chlorpyrifos, MCCPs and long-chain PFCAs, along with Dechlorane Plus and UV-328, from 16 December 2026. The consultation has closed, and the instrument has not yet been made.

And the queue behind them is forming. At its September meeting, the Convention’s POPs Review Committee considered Norway’s nomination of decabromodiphenyl ethane (DBDPE) and the EU’s nomination of TBPH; according to ECHA, both have moved to the risk-profile stage. DBDPE is worth a second look: its use grew largely as a replacement for decaBDE, which the Convention listed in 2017. More on that pattern below.

What not to miss

• For agricultural, wood-based and recycled inputs from markets where chlorpyrifos is still used, hold supplier declarations or analytical evidence below 0.01 mg/kg. The prohibition already applies.
• If you haven’t already, request batch-level MCCP data from chlorinated-paraffin suppliers now, and check use by use whether an exemption covers you before 16 December.
• If you supply chlorinated paraffins, schedule the SDS update for MCCP content ahead of the December date.

Sources: EUR-Lex — Delegated Regulation (EU) 2026/1423 · Council of the EU — C(2026) 6262 (MCCPs) and C(2026) 6059 (PFCAs) · Defra — draft POPs (Amendment) Regulations 2026 · Stockholm Convention — POPRC meeting page

2. Quiet CLP

The 1 November deadline for the new CLP hazard classes has been on everyone’s calendar for many months now, and it is now only weeks away. Under Delegated Regulation (EU) 2023/707, substances already on the market must be classified, labelled and supported by safety data sheets reflecting the endocrine disruptor (ED HH, ED ENV), PBT/vPvB and PMT/vPvM hazard classes by 1 November 2026. Mixtures follow on 1 May 2028. This is self-classification, so the duty does not wait for harmonised entries.

What changed in September is that there is now something to measure against. Two things, in fact. In the summer issue we reported RAC’s opinion on resorcinol: ED HH Category 1 (EUH380), on the basis of thyroid effects, the first under the human-health ED class. ECHA published it on 11 September 2026.

Then, at its September plenary (RAC-78, 7–11 September), RAC adopted its opinion on propyl paraben (propyl 4-hydroxybenzoate), recommending classification as an endocrine disruptor for the environment, Category 1 (EUH430), and went one step further than the dossier submitter on aquatic toxicity, to Aquatic Chronic 2 (H411). It is the first time RAC has applied the ED criteria for the environment.

Neither opinion is binding until the Commission brings it into Annex VI through an ATP. Until then, a self-classification that leaves out the hazard RAC has just recommended will be hard to defend with that opinion on the public record.

A second CLP file is running late. Article 37(7) of the revised CLP Regulation requires the Commission to move substances already identified as endocrine disruptors or as PBT/vPvB under other frameworks – the REACH Candidate List, the Plant Protection Products Regulation and the Biocidal Products Regulation – into harmonised classification. The legal deadline was 11 June 2026, and it was missed. At the July CARACAL meeting the Commission said it intends to adopt the transfer regulation as soon as possible, without a further round of discussion in the autumn. A public consultation will still run, and it will be the only opportunity to contest a classification before it becomes binding under CLP. An 18-month transition is the working assumption, not a confirmed figure. For substances whose ED or PBT status was contested under BPR or PPPR, that consultation is the last door.

Then there are poison centres. On 14 September, ECHA’s Poison Centres site confirmed that from 1 January 2027 distributors are explicitly duty holders under CLP Article 45. A distributor that relabels or rebrands a hazardous mixture, or supplies it into a Member State where no notification exists, must submit its own PCN unless it can show the appointed body already holds the same information. ECHA presents this as a clarification rather than a new obligation. For a distributor who assumed PCN was the supplier’s problem, the practical effect is the same either way. ECHA also corrected its Annex VIII guidance: the EU importer is responsible for the UFI on the label, although a non-EU supplier may pre-label using the importer’s UFI. For a distributor supplying the same mixture into both Czechia and Slovakia, the question is simply whether a notification exists in each market, and who made it.

What not to miss

• Complete self-classification against the new hazard classes and issue updated labels and SDSs before 1 November. Suppliers of resorcinol or propyl paraben: check your self-classification against the RAC opinions. Downstream users should expect revised SDSs.
• Screen your portfolio for substances with an ED, PBT or vPvB determination under REACH, BPR or PPPR, and prepare the evidence now. When the Article 37(7) consultation opens, the window will be short.
• Distributors and private-label owners: map relabelled and cross-border lines before year-end, confirm that a notification covers each market, and ask suppliers for PCN submission reports alongside SDSs.

Sources: EUR-Lex — Delegated Regulation (EU) 2023/707 · ECHA — RAC-77 minutes · ANSES — resorcinol CLH proposal · ECHA — RAC-78 minutes · EUR-Lex — Regulation (EU) 2024/2865 · Keller and Heckman via The National Law Review — Article 37(7) · ECHA Poison Centres — distributors’ obligations

3. Replacements questioned

Two September items tell the same story from different ends. When a substance is restricted, supply chains move to the nearest alternative that works. Some years later, the alternative gets the same scrutiny.

PFHxA is the clearest case: many supply chains moved to PFHxA-based chemistry when PFOA was restricted. From 10 October 2026, REACH Annex XVII entry 79, introduced by Regulation (EU) 2024/2462, applies to the first group of consumer uses: textiles, leather and fur in clothing and accessories, footwear, paper and board for food contact, consumer mixtures such as waterproofing sprays, and cosmetics. The limits are 25 ppb for PFHxA and its salts and 1 000 ppb for PFHxA-related substances, measured in homogeneous material. Non-clothing textiles follow on 10 October 2027. The restriction applies at the point of placing on the market, so anything first placed after 10 October must comply, regardless of when it was made. We made the same point about the PPWR packaging limits in the summer issue; it holds here too.

Bisphenol F is earlier in the same cycle. ECHA’s 30 September update lists a new intention to identify 4,4′-methylenediphenol (bisphenol F, EC 210–658–2) as a substance of very high concern, submitted by Sweden on grounds of reproductive toxicity. An intention is only the first step. An Annex XV dossier, a public consultation and Member State Committee agreement all come before any Candidate List entry. But it does not stand alone. Bisphenol F is among the 20 substances in HSE’s proposed revision of the GB mandatory classification list, which we covered in the summer issue, and environmentally endocrine-disrupting bisphenols sit in Annex I of the Commission’s REACH Restrictions Roadmap. Bisphenol F is widely used in epoxy resins and coatings, often as the alternative to bisphenol A. Companies that swapped one bisphenol for another should expect the same questions to follow.

The Roadmap is worth reading with this pattern in mind. The Commission presented the revised version on 2 July. It counts 11 REACH restrictions adopted since 2022 and six more in the final stages, including lead in fishing tackle, which received a positive REACH Committee vote in April, and lead in ammunition, which is still under discussion. Three proposals are with ECHA’s committees: the universal PFAS restriction, Cr(VI) in industrial uses and octocrylene in cosmetics (which has since cleared both committees, see story 5). On PFAS, SEAC’s final opinion is still expected by the end of 2026, with a Commission decision unlikely before 2027. Annex I lists 13 (groups of) substances with work under way towards possible restrictions, among them non-polymeric aromatic brominated flame retardants (dossier expected December 2026), environmentally endocrine-disrupting bisphenols and 6PPD in tyres (both March 2027). None of that is binding. It is, however, the closest thing to a published list of what your substitutes may face next.

What not to miss

• Confirm test data against the 25 ppb and 1 000 ppb limits for every in-scope line, and obtain supplier declarations where you do not test yourself.
• Map where bisphenol F sits in your portfolio.
• Before settling on an alternative, check it against the Roadmap annexes. A substitute already listed in Annex I is a short-term fix.

Sources: EUR-Lex — Regulation (EU) 2024/2462 · ECHA — Registry of SVHC intentions · HSE — GB MCL list · European Commission — revised REACH Restrictions Roadmap, 2 July 2026 · European Commission — Restrictions Roadmap rolling list

4. Beyond the EU

Serbia amended its chemical restrictions regulation in Official Gazette No. 82/2026–28, published on 4 September and in force from 12 September. Methoxychlor, UV-328 and Dechlorane Plus join the list of prohibited persistent organic pollutants, with tiered concentration limits and transitional periods. The amendment also covers the diisocyanate restrictions, in line with REACH Annex XVII entry 74, including documented training for industrial and professional users. Read alongside the EU listings in story 1, the direction is plain: Serbia is closing the distance to the EU acquis one substance at a time. Exporters who counted on a lighter regime across the border have less room than they did in August.

Ukraine’s timeline has settled following Resolution No. 1598. Pre-registration under UA REACH is open until 26 January 2027. The first registration deadline – CMR 1A/1B substances at one tonne or more per year and Aquatic Chronic 1 substances at 100 tonnes or more – has moved to 1 October 2028, and mandatory classification under UA CLP applies from 15 November 2027. The transitional period that lets chemical products placed on the market before 26 January 2025 continue to be supplied runs for two years from the regulation’s entry into force, so it closes on 26 January 2027, the same day pre-registration ends. There is still enough time to pre-register, but not if the work starts in January.

Great Britain has put its new registration model into draft legal text. In the summer issue we noted that the requirements of the Alternative Transitional Registration model (ATRm) were still undefined. Defra is now consulting, until 10 November, on a draft statutory instrument amending UK REACH. Transitional registrants would submit less hazard information upfront, including classification and safe-use information, and HSE would gain powers to request more where it needs it. The registration deadlines stay as set this summer, from October 2029 to October 2031.

What not to miss

• Screen products shipped to Serbia against the three new POP entries and check how the diisocyanate training requirement is met for your industrial and professional customers.
• Ukraine: start pre-registration now; it closes on 26 January 2027.
• GB: if you rely on transitional UK REACH registrations, check your portfolio against the draft ATRm conditions and comment by 10 November.

Sources: Official Gazette of Serbia 82/2026 · Cabinet of Ministers of Ukraine — Resolution No. 1598 · Ministry of Economy of Ukraine · GOV.UK — UK REACH ATRm technical consultation

5. Back from committee week

The summer issue’s calendar pointed to three ECHA committee meetings in the first half of September. Here is what came back.

RAC (7–11 September). Besides the propyl paraben opinion above, RAC concluded that the Ramazzini Institute’s 2025 st­udy does not change its 2022 assessment: glyphosate does not warrant classification for carcinogenicity. It is the third time RAC has reached that conclusion (2017, 2022, 2026). The opinion goes to the Commission.

BPC (7–10 September). Most notably, the committee adopted opinions on including Arnica montana extract in Annex I of the BPR and renewing hexaflumuron as an insecticide (PT 18). The Commission takes the final decisions.

SEAC (15–16 September). SEAC adopted its final opinion on France’s proposal to restrict octocrylene in finished cosmetic products. With RAC’s opinion adopted in June, both of ECHA’s committees are done, and the decision now passes to the Commission. On chromium(VI), SEAC worked through the consultation comments on its draft opinion and plans to adopt its final opinion at its next meeting.

Already on the calendar

A few dates ahead, labelled by status. Since the summer issue, ECHA’s committees have met (see story 5) and the PIC expansion to 34 chemicals applied on 1 October.

10 October 2026 — PFHxA restriction applies to the first consumer uses >BINDING

REACH Annex XVII entry 79. Non-clothing consumer textiles follow on 10 October 2027.

10 October 2026 — Toy Safety Directive amendment: comments close >CONSULTATION

The draft covered in the summer issue: Lilial prohibited, and a lower bisphenol A migration limit for toys for young children.

16 October 2026 — CLP adaptation to GHS Revisions 8–10: comments close >CONSULTATION

Also covers selected provisions of Revision 11. Adoption is planned for the fourth quarter of 2026.

1 November 2026 — New CLP hazard classes for substances on the market >BINDING

Self-classification against ED, PBT/vPvB and PMT/vPvM, with updated labels and SDSs. Mixtures follow on 1 May 2028.

5 November 2026 — ECHA webinar for SMEs on reduced fees >EVENT

ECHA’s second SME session this autumn, after the one on poison-centre notifications on 23 September.

10 November 2026 — UK REACH ATRm draft legal text: comments close >CONSULTATION

Defra’s draft statutory instrument for the alternative transitional registration model.

16 December 2026 — MCCPs and C9–C21 PFCAs under the EU POPs Regulation >ADOPTED · SCRUTINY PERIOD RUNNING

Applies once the Parliament and Council scrutiny period ends without objection.

1 January 2027 — Distributors as poison-centre duty holders >BINDING

CLP Article 45, as confirmed by ECHA on 14 September.

26 January 2027 — UA REACH pre-registration closes >BINDING

The two-year transitional period for chemical products placed on the market before 26 January 2025 ends the same day.

Further out

• 11 May 2027 — 2,4-dinitrotoluene restriction begins (REACH entry 83) · phased to 2029
• 6 August 2027 — Formaldehyde emission limits extend to vehicle interiors (entry 77)
• 10 October 2027 — PFHxA restriction extends to other consumer textiles
• 1 May 2028 — New CLP hazard classes apply to mixtures
• Q3 2028 — Revised GB mandatory classification list becomes mandatory (proposal)
• 1 October 2028 — First UA REACH registration deadline
• 27 October 2029 — First UK REACH transitional registration deadline

In September we ran Part 4 of Let’s talk EU REACH, covering CLP changes, biocides, the C&L Inventory and labelling, with Jana Eliášová and Yana Trubitsyna, and spoke at the Chemical Legislation in Practice conference in Novi Sad. Past webinars can be found on our YouTube.

For our Czech readers: Chemická legislativa 2027 takes place on 27 January 2027 in Prague. Save the date.

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And just like that, it’s a wrap. Thank you for reading, and thank you to Jana Eliášová and Yana Trubitsyna for their contributions.