ECHA public consultation: CLH proposal for C4-C6 ortho-phthalates

On 28 January 2026, European Chemicals Agency (ECHA) published a dossier to propose harmonised classification and labelling (CLH) of a group of C4–C6 ortho-phthalates (Dossier Submitter: France) and launched the public consultation. European Plasticisers reviewed the dossier and submitted comments on the public consultation accordingly.

In our submission, we particularly stressed the following points:

• Any new CLH entry must be legally robust, scientifically justified, coherent, transparent and enforceable, in line with the requirements of the EU CLP Regulation, in accordance with CLP Regulation Article 37 (8).
• The dossier’s grouping and scope definition raises questions in terms of clarity and predictability (for industry, authorities, and enforcement authorities), notably in the absence of an explicit listing of individual substances with their CAS and EC numbers.
• The criteria for the endocrine disruptor (ED) hazard class in the CLP do not appear to be fulfilled. There is no systematic assessment and documentation of the link between the proposed endocrine mode of action and the adverse effects; rather, the link is assumed.
• The read-across approach in the dossier does not follow the ECHA Read-Across Assessment Framework (RAAF), and raises significant concerns regarding its robustness. In our view, the dossier provides no meaningful added value for protecting human health or the environment. This is because it largely targets substances that are already heavily regulated, no longer commercial, or non-viable alternatives, while risking unintended regulatory consequences that could undermine the well-established safe use of high molecular weight phthalates.

Following the submission of our comments, we remain committed to maintaining a constructive dialogue with authorities and stakeholders to support a scientifically sound, legally robust and proportionate outcome under the CLP Regulation.

ECHA website – Registry of Intention: Registry of CLH intentions until outcome - ECHA