Hazard lists and regulatory lists for chemicals

Hazard lists and regulatory lists for chemicals

In chemical management, having an overview is crucial. Organisations must know which chemicals are in use, what inherent hazards they present, and which legal requirements apply. To manage chemical risks in a systematic and documentable way, a number of hazard lists and regulatory lists have been established.

Hazard lists and regulatory lists identify substances with particularly hazardous properties, regulate their use and placing on the market, and provide guidance for substitution, reporting, and risk assessment. This article explains what these lists are, how they relate to each other, and what they mean in practice.

What is meant by hazard lists and regulatory lists?

Hazard lists and regulatory lists are two closely connected mechanisms within chemicals legislation. Hazard lists identify substances with particularly problematic properties. Regulatory lists set out specific legal requirements related to these substances, such as information obligations, authorisation requirements, or prohibitions.

For organisations, this means they must both understand the risks associated with the substances they use and be aware of the legal obligations that apply. Together, the lists form the basis for sound chemical management and compliance with regulatory requirements.

The difference between hazard and regulation

Hazard relates to the inherent properties of a substance, for example whether it is carcinogenic, toxic for reproduction, or persistent in the environment. Regulation concerns the legal consequences of these properties.

A substance may be hazardous without being prohibited, yet still be subject to information obligations or expectations of phase-out. This distinction is essential for correct risk assessment and compliance.

Hazard lists

Hazard lists are based on scientific assessments and are used to identify substances that should be prioritised in risk assessment and substitution efforts. Typical criteria include:

  • CMR properties (carcinogenic, mutagenic, or toxic for reproduction)
  • PBT/vPvB (persistent, bioaccumulative, and toxic substances)
  • Endocrine-disrupting properties

Hazard lists function as an early warning system. Inclusion does not necessarily mean prohibition but signals increased regulatory attention.

Examples of hazard lists

  • Harmonised classification — CLP Annex VI
  • The IARC list (cancer hazard)
  • PBT and vPvB identification

Regulatory lists

Regulatory lists are directly anchored in legislation and specify which substances are subject to concrete requirements or prohibitions.

The central framework in the EU and EEA is the REACH Regulation. REACH is based on the principle that companies themselves are responsible for documenting safe use (“No data – no market”).

Examples of regulatory lists

  • REACH Candidate List
  • Authorisation List
  • Restriction List
  • Norwegian Priority List

How hazard lists and regulatory lists are connected

Regulation often occurs stepwise: a substance is first identified as problematic, placed on a candidate list, and may later become subject to authorisation or restrictions.

For organisations, this means chemical management is dynamic. A substance that today appears only on a hazard list may later become strictly regulated. This requires continuous oversight.

REACH’s three key lists

Candidate List (SVHC List)

The candidate list contains substances identified as SVHC (Substances of Very High Concern), i.e. substances with particularly serious properties. These can, for example, be carcinogenic, harmful to reproduction, persistent and bioaccumulative or endocrine disruptors.

When a substance is added to the candidate list, a duty of disclosure is triggered. In other words, the supplier must provide information about the presence of such substances above certain concentration limits. In addition, it creates a clear expectation that companies consider the substitution of products containing such substances. The candidate list therefore serves as an initial warning that stricter measures may be forthcoming.

Authorisation List

The authorisation list (REACH Annex XIV) contains substances that cannot be used without specific authorisation. Authorisation requires a comprehensive application, documentation of risk and assessment of alternative solutions.

If a substance is included on the Authorisation List, it is a clear signal that it is being phased out of the market. For many organisations, this means substitution becomes the most realistic solution in practice.

Restriction List

The restriction list (REACH Annex XVII) contains specific restrictions or bans on certain substances or areas of use. Restrictions may, for example, be that a substance is not permitted in consumer products, that concentration limits apply, or that its use is restricted to certain industries.

Norwegian Priority List

Norway also has a national priority list of pollutants that is managed by the Norwegian Environment Agency. The list is actively used in inspections and can often be stricter than the EU’s minimum requirements.

Today, the list includes 85 substances and substance groups, including:

  1. Heavy metals: Persistent metals that can accumulate in organisms and cause serious health and environmental damage.
  2. Endocrine-disrupting substances: Affect the hormonal system and may cause reproductive and developmental harm.
  3. Flame retardants: Used to reduce fire risk, but several are persistent and bioaccumulative.
  4. Per- and polyfluoroalkyl substances (PFAS): Highly persistent substances that degrade slowly and can accumulate in the environment and humans.
  5. Organotin compounds: Toxic substances that can harm aquatic organisms and affect the hormonal system.
  6. Polycyclic aromatic hydrocarbons (PAHs): Compounds often formed during combustion, several of which are carcinogenic.
  7. UV stabilisers: Used to protect materials from sunlight; some are persistent and potentially endocrine disrupting.
  8. Dioxins and furans: Highly toxic and persistent compounds that can form as by-products in industrial processes.
  9. Siloxanes: Used in cosmetics and technical products; some are highly persistent and bioaccumulative.
  10. Chlorinated organic substances: Often persistent and bioaccumulative compounds with significant environmental and health risks.
  11. Other organic substances: A collective group for organic compounds with serious and long-term environmental effects.

New substances are continuously assessed, and the list is updated on an ongoing basis.

Hazard lists and regulatory lists give businesses insight into both risk and regulation. Understanding the difference between the inherent properties of substances and the legal framework that applies makes it easier to make the right choices in practice. Chemical management is constantly evolving. New substances are assessed, lists are updated and requirements change. To maintain control, companies must have an up-to-date overview, structured documentation and good systems for assessment. Digital solutions such as Workplace Safety bring this information together in one place and make it easier to work systematically with safe and forward-looking chemical management.

Common challenges with chemical storage – and how to avoid them

Common challenges with chemical storage – and how to avoid them

Improper storage of chemicals and hazardous substances increases the risk of accidents, environmental damage and, in the worst case, regulatory breaches. Here we have gathered some of the most common challenges related to chemical storage, and how you can ensure safe chemical management in your organisation.

Inadequate labelling and documentation

One of the most widespread challenges is incorrect or inadequate labelling of products. When hazard symbols and labels are missing or difficult to read, it can lead to confusion or incorrect handling of chemical substances. Therefore, make sure that hazardous chemicals are labelled with clear hazard labels in accordance with CLP regulations, and that safety data sheets (SDS) are updated at all times.

Unsuitable storage conditions

Unsuitable storage conditions can create dangerous situations. Many chemicals can react to heat, moisture or direct sunlight, increasing the risk of leaks, explosions or fire. Therefore, ensure that chemicals are stored at the correct temperature, not in overheated rooms or near heat sources or machinery, and that storage areas have adequate ventilation.

Lack of overview of flammable and explosive substances

Many organisations lack a consolidated and up-to-date overview of flammable and explosive substances. This can make it difficult to assess risks, control storage quantities and ensure appropriate preventive measures. Without a good overview, the risk of incorrect storage, undetected ignition sources and inadequate emergency preparedness in the event of fire or explosion increases.

Insufficient training and safety and emergency procedures

Even the best chemical management systems are of little use if employees do not know how to use them. Lack of training can lead to incorrect handling, especially in the event of leaks or incidents. Therefore, ensure that clear procedures are in place for risk assessment, chemical handling and emergency situations, and that all employees receive the necessary training.

Outdated or inadequate equipment

If equipment is old, worn or no longer suited to the chemicals being stored, the risk of hazardous situations increases. Ensure that there are fixed routines for inspection, maintenance and replacement of equipment, and that employees have the correct protective equipment for their work.

Incorrect waste handling

Improper handling of chemical waste can lead to environmental damage and fire hazards. Unfortunately, many organisations lack clear procedures for how hazardous waste should be collected, labelled and stored. Therefore, ensure you have a clear waste management plan, use approved containers and label waste correctly. Waste collection should be arranged with certified waste management companies.

Storage of incompatible chemicals

Certain chemicals must never be stored together, as they can react dangerously with each other. Incorrect co-storage is one of the most common causes of serious accidents. Therefore, divide storage areas by substance type and hazard class. Use separate cabinets or rooms, and label clearly to prevent dangerous chemical reactions.

Examples of incompatible substances:

  • Acids and bases
  • Oxidising substances and flammable liquids
  • Chlorine and ammonia

Manual systems

Many organisations still use manual systems or unclear Excel lists for chemical management. This can increase the risk of errors, lack of updates and poor oversight. This can be avoided by implementing automated systems that provide full oversight of chemicals, documentation, storage conditions and waste management.

Digital tools can solve some of the challenges

By using a digital tool such as Workplace Safety, the company gets a comprehensive and up-to-date overview of chemicals and associated documentation. The system provides guidance on co-storage and alerts you to potential storage hazards, based on the German standard TRGS 510 for co-storage. It is also easy to look up the safety data sheet directly in the system, so requirements for handling, storage and stability are quickly available.

Chemical management is primarily about order, structure and good routines. By ensuring clear labelling, correct storage conditions, suitable equipment and simple, up-to-date systems, daily operations can become both safer and more efficient. Small improvements in routines can make a big difference.

New hazard classes in the CLP regulations

New hazard classes in the CLP regulations

Improved chemical safety with new hazard classes in the CLP regulations

In April 2023, updates to the EU CLP regulation (classification, labelling, and packaging) came into force. The update introduced new classifications of chemicals, with a focus on endocrine-disrupting properties and environmental risks, including bioaccumulative properties and potential water pollution.

Classification and labelling is a key tool for reducing risk in chemical use. Over time, it encourages the replacement of the most hazardous substances with safer alternatives.

The new hazard classes include:

  • Endocrine disrupting properties: Chemicals that affect the endocrine system, potentially causing health issues such as birth defects and development disorders in humans and wildlife.
  • Persistent, bioaccumulative and toxic properties (PBT and vPvB): Substances that break down slowly in the environment and build up in organisms and food chains.
  • Persistent, mobile and toxic properties (PMT and vPvM): Substances that combine high persistence with mobility, spreading rapidly in the environment, often through waterways.
CodeH-phrases
EUH380May cause endocrine disruption in humans
EUH381Suspected of causing endocrine disruption in humans
EUH430Can cause endocrine disruption in the environment
EUH431Suspected of causing endocrine disruption in the environment
EUH440Accumulates in the environment and living organisms, including humans
EUH441Highly accumulates in the environment and living organisms, including humans
EUH450Can cause long-term and diffuse pollution of water resources
EUH451Can cause very long-term and diffuse pollution of water resources

Significance of the changes

The new hazard classes strengthen the regulation of substances with these properties, ensuring that hazardous chemicals are handled in the same way as other serious hazards. This may results in stricter requirements for companies and limitations on how these substances can be used. The changes will also influence related legislation, including rules on biocides, pesticides, cosmetics, and occupational health and safety.

New obligations for companies

Chemical suppliers are now required to review their chemicals and determine whether they fall under the new hazard classes. If so, they must update their registrations with the European Chemicals Agency (ECHA) and ensure that everyone in the supply chain receives up-to-date safety information. For new substances, the rules apply from May 1, 2025, while existing substances have until November 2026. There are also transition periods in place for mixtures.

REACH – Implementation phases of classification and labeling of new hazard classifications.
Source: https: //echa.europa.eu/new-hazard-classes-2023

Guidance and support

The introduction of the new hazard classes is an important step in strengthening the protection of health and the environment from hazardous chemicals. ECHA is updating its guidance to reflect these changes, and companies can follow the process and access resources directly on the ECHA website.

What does this mean for your chemical management?

Your company should ensure it has a clear overview of whether any products fall under the new chemical classifications. Contact the suppliers of your chemical products for updated information, and keep track of changes to the safety data sheets, especially if your company uses automatic updates in the chemical inventory.

If products are covered by the new classifications, a new risk assessment must be carried out. This includes evaluating whether additional protective measures are required to ensure that the use and storage of the substances remain at an acceptable risk level, in line with your company’s safety criteria.

Written by Hans Kristian Brekken, chemist and product developer at Workplace Safety.