EU REACH: restrictions for F-Gases and PFAS in electronics

The European Chemical Agency’s (ECHA) Committees for Risk Assessment (RAC) and for Socio-Economic Analysis (SEAC) continue their review of the EU-wide proposal to restrict per- and polyfluoroalkyl substances (PFAS).

Both committees reached provisional conclusions for applications of fluorinated gases (F-gases).

F-gases are used in common products, equipment and processes, such as refrigeration, air conditioning, heat pumps, insulation, fire protection, aerosol propellants, as well as in industrial processes – and are therefore relevant to many of Landbell Group’s clients.

In June 2025, the committees will continue sectoral use assessments of the proposed PFAS restriction – electronics and semiconductors are two sectors that might be particularly relevant to Landbell Group clients.

The European Commission is committed to phasing out PFAS through a sector and use specific approach.

In September 2024, they restricted the use of undecafluorohexanoic acid (‘PFHxA’) and PFHxA ‑related substances, a sub-group of PFAS chemicals, giving transitional periods of between 18 months and 5 years, depending on the use, to allow time for replacement by safer alternatives.

UK REACH: new fees and adjustments effective April 2025

The UK Government has announced new fees and charges for UK REACH, effective from 1 April 2025.

These changes, detailed in a recent Statutory Instrument, aim to align fees with the operational costs of the Health and Safety Executive (HSE) and ensure compliance with government guidance.

Key changes include:

  • Registration fees
  • Tonnage upgrade fees
  • Product and process orientated research and development (PPORD) notification fees, and
  • Authorisation fees

The changes provide savings for most businesses, especially those with large registrations, though companies in the 1-10 tonnage band will experience higher costs.

Companies planning registrations or authorisations should budget accordingly.

For more information, please see the full article by H2 Compliance.

USA: TSCA Risk Management Program

Under the new administration, it is expected that implementation of the Toxic Substances Control Act (TSCA) could be significantly different from past activity.

What are the likely implications on regulating existing chemicals under TSCA Section 6 in 2025?

A recent article by Landbell Group company, H2 Compliance offers an in‐depth analysis of the TSCA Risk Management Program (RMP), highlighting both its evolution and the emerging challenges for chemical manufacturers and stakeholders.

The analysis focuses on the following areas:

  • General process
  • Recent activity for risk evaluation and management in 2024
  • The Workplace Chemical Protection Program (WCPP), and
  • Persistent, bioaccumulative and toxic substances (PBTs)

In summary, the EPA’s approach to regulating existing chemicals under TSCA remains uncertain, but all regulated parties should expect new or evolving requirements.

Stakeholders must stay aware of regulatory changes and invest time and resources to update their TSCA compliance programs accordingly.

If you need assistance navigating TSCA regulatory developments, please contact H2 Compliance.

European chemical identifiers – format update

Anyone using chemical substances in their industrial processes is familiar with the official numerical identifiers: the Chemical Abstracts Service (CAS) and European Community (EC) numbers.

CAS Registry Numbers

Globally used CAS Registry Numbers are unique numerical identifiers assigned by the US-based CAS to every chemical substance described in the open scientific literature.

EC Numbers

European EC numbers originate from different pieces of historical legislation. List numbers are purely technical identifiers assigned to substances without an EC number registered or notified under the REACH or CLP Regulations.

EC and list numbers are used to ensure that data for the same substances is consistently grouped through regulatory processes.

The current format of both EC and list numbers is six numerical characters and one calculated check digit.

As the list numbers in their current format will run out, the format will become alphanumerical, replacing the first digit with a letter, keeping the same length.

Once all letters are used in the first position, the second character will become a letter, and so on:

  • Example of the current list number: 100-000-1
  • Example of the new list number: A00-001-5