REACH reform – insights paper

The document outlines the distinctions between 'most harmful substances', 'substances of very high concern', 'substances of concern', and 'hazardous substances' under EU regulations, while providing estimates on the scale of the global and EU chemical markets.

• The 'most harmful substances' (MHS) are defined by the Chemical Strategy for Sustainability as chemicals that cause cancers, gene mutations, affect the reproductive or endocrine system, or are persistent and bioaccumulative, as well as those affecting the immune, neurological, or respiratory systems and chemicals toxic to a specific organ.
• Substances of very high concern (SVHC) are defined by Art. 57 of REACH and include carcinogenic, mutagenic, and toxic for reproduction substances (category 1 A and B), as well as persistent, bioaccumulative and toxic (PBT) and very persistent and very bioaccumulative (vPvB) substances. This category is considered broader than 'most harmful substances' due to a safeguard provision for properties of 'equivalent concern' to catch emerging risks.
• The term 'substance of concern' is used in the proposal for the Ecodesign for Sustainable Products Regulation (ESPR) and the reform of the Packaging and Packaging Waste Directive. It encompasses substances that meet SVHC criteria, specific hazard classes under the CLP Regulation, or substances that negatively affect the re-use and recycling of materials, even if they are not toxic.
• Hazardous substances, as defined in Annex I of the CLP Regulation, include physical hazards like explosives, as well as health and environmental hazards such as acute toxicity, skin corrosion, and ozone layer hazards.

APA

Roger, A. (2023). REACH reform – insights paper. ClientEarth. https://www.clientearth.org/media/s4gepejh/ce_reach-reform_typology_hazardous_substances.pdf

Chicago

Roger, Apolline. REACH reform – insights paper. ClientEarth, 2023. https://www.clientearth.org/media/s4gepejh/ce_reach-reform_typology_hazardous_substances.pdf.

Wikipedia

{{cite report |last1=Roger |first1=Apolline |title=REACH reform – insights paper |publisher=ClientEarth |date=March 2023 |url=https://www.clientearth.org/media/s4gepejh/ce_reach-reform_typology_hazardous_substances.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{roger2023reach, author = {Roger, Apolline}, title = {{REACH reform – insights paper}}, institution = {ClientEarth}, year = {2023}, month = mar, url = {https://www.clientearth.org/media/s4gepejh/ce_reach-reform_typology_hazardous_substances.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }