ROHS Compliance

On November 27, 2025, the European Commission submitted notification G/TBT/N/EU/1172 to the WTO Technical Barriers to Trade Committee, outlining planned technical amendments to the CLP Regulation (EC 1272/2008). The proposal introduces 38 new entries and updates 10 existing entries in Annex VI.

Key Updates

1. Additions and Revisions to Annex VI

Annex VI, Table 3 has been updated to include new harmonised classifications for several substance groups, such as:

· Borates (e.g., potassium metaborate, sodium octaborate, magnesium metaborate) → Classified as Reproductive Toxicity Category 1B.

· Phosphonates (e.g., sodium and potassium salts of ethylenediaminetetramethylphosphonic acid) → Classified as Carcinogenicity Category 1B.

· Phenols and Ketones (e.g., Bisphenol F, 4-phenylbenzophenone) → Updated classifications include Reproductive Toxicity Category 1B, skin sensitization, and chronic aquatic toxicity.

· Acids and Esters (e.g., propylene glycol monomethacrylate, perfluorohexanoic acid) → Classified under categories such as Reproductive Toxicity Category 1B and STOT – Repeated Exposure Category 2.

2. Introduction of New Note 13

A new Note 13 specifies that mixtures containing a common molecular entity (bromide ion) must calculate hazards based on the summed concentration of relevant bromide salts. If the total concentration exceeds a defined threshold, the mixture must be classified as Reproductive Toxicity Category 1.

Implementation Timeline

· The regulation is expected to be adopted in Q1 2026.

· It will become effective 20 days after publication in the Official Journal of the EU.

· An 18-month transition period will be provided to industry.