German Environment Agency Proposes PMT And vPvM Criteria Under REACH And CLP

Posted on: April 12, 2018

Last month, the German Environment Agency (UBA) and the Norwegian Geotechnical Institute (NGI) hosted a workshop on “PMT and vPvM substances under REACH” in Berlin, Germany. The two day event – which was attended by more than 120 people from 16 different countries – saw proposals made to identify Persistent, Mobile, and Toxic (PMT) and very Persistent and very Mobile (vPvM) substances under the REACH Regulation.


UBA began discussions regarding potential criteria for PMT and vPvM substances back in 2009, which was followed by a first round of workshops in 2012 on how to improve drinking water protection. The second draft paper outlining UBA’s proposals was published in October 2017, and will be further refined based on the feedback of this workshop.

What happened at the workshop?

During the two day event in Berlin, UBA proposed criteria and an assessment procedure to identify PMT and vPvM substances that pose a hazard to the sources of drinking water, and invited the chemical industry, drinking water suppliers and regulatory bodies to participate in a discussion of voluntary measures and regulatory options to protect drinking water sources.

NGI consultant Professor Dr. Hans-Peter Arp presented the results of a project which applied the UBA’s PMT and vPvM criteria to REACH registered chemicals, resulting in a list of 240 substances being identified as PMT vPvM and/or having high potential to be PMT or vPvM. Proof of concept was provided by finding 45 out of 70 (64%) of the PMT/vPvM chemicals in drinking water samples tested, even though many of the target chemicals had never before been identified in water sources.

Industry viewpoints

Dr. Ronald Bock of Chemours represented the European Chemical Industry Council (CEFIC) position on the topic, and emphasized the need for better scientific data – especially risk assessment – before rushing into aggressive regulations similar to the treatment of Persistent, Bioaccumulative and Toxic (PBT) and very Persistent and very Bioaccumulative (vPvB) under REACH.

This was countered by UBA’s Dr. Michael Neumann, stating that “we really don’t need more monitoring to start acting”.

Dr. Sylvain Bintein, Policy Coordinator for the European Commission Directorate General for the Environment, closed the workshop with an overview of every option he could think of using existing regulations or potential amendments to address the risk of PMT/vPvM substances. With the caveat that these are not an official position of the Commission (because there is not yet any petition to address PMT/vPvM issues), Dr. Bintein launched into an extensive survey of options including:

  1. Applying provisions currently in REACH to PMT/vPvM characteristics:
  • Address drinking water contamination as “secondary poisoning” in dossiers
  • Interpret section 0.10 of Annex I of REACH on particular effects such as ozone depletion or strong odors to improve evaluations of data for persistence and mobility
  • Case-by-case designation of PMT/vPvM substances as Substances of Very High Concern (SVHC) candidates under Article 57(f) provisions on equivalent level of concern
  • As a last resort: the precautionary principle could be applied (this has not yet been used under REACH)
  1. A possible first step of adding a new hazard class for PM substances to the UN GHS/CLP.
  2. Amending REACH by adding P, M, T criteria to key provisions.
  3. Amending CLP to add a PM hazard class to Annex I, or to add PMT classifications to the harmonized classification and labeling in Annex VI.

Next Steps

If you would like to see a detailed report on the proceedings of the workshop, with links to the UBA Proposal and the NGI list of PMT candidate substances, you can do so here.

UL’s global Regulatory Assurance Team includes a number of leading industry experts on REACH, GHS and CLP who can help you navigate the complex, ever changing regulatory landscape to understand and execute your compliance obligations. You can take a look at our full range of Advisory Services, and talk to an expert, here.

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Useful Information

UBA Proposal “Protecting The Sources Of Our Drinking Water” October 2017 (PDF)


German Environment Agency (UBA)

Norwegian Geotechnical Institute (NGI)




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