Cumene content in UVCB hydrocarbon solvents
Cumene is included via the 18th ATP to the Classification and Labelling Regulation (CLP) as carcinogen 1B with entry into force by 1st December 2023. This triggered some obligations with respect to supply chain communication and labelling and led to questions from several downstream users, especially since some companies have already started to change their SDS, and others are still waiting. All category 1, 2, or 3 substances could be impacted depending on whether they contain more or less than 0.1% cumene. As a general principle, formulators can apply dilution factors to consider the amount of cumene in their mixtures and then classify or not classify their formulation according to CLP.
A dedicated document explaining the situation has been developed and can be consulted. We will update this paper with time.
N-hexane Reclassification
The German Competent Authority, BAuA, had submitted a proposal for harmonised classification, making n-hexane STOT RE 1. The industry does not object to this. However, a specific concentration limit (SLC) should be kept at 5%. Many formulations and industrial processes are built on the 5%, and the naming convention uses this as criteria. An opinion was provided earlier this year during the public consultation. The Risk Assessment Committee (RAC) at ECHA decided not to discuss this further and conduct the opinion-making in writing.
Aspiration Hazard
After HSPA tried several years unsuccessfully to gather enough information to potentially change at least the label for aspiration hazard, the main point is to correct or avoid misinterpretation (aspiration hazard being a phys chem based hazard and not a pure health hazard). HSPA filed a derogation request for all substances and mixtures with this classification under the EU Ecolabel for absorbent hygiene products.