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PCA - ARN Task Force

The PCA is diligently working with HARRPA and H4R on the ongoing classification and labeling assessment of rosin and rosin derivatives. We will continue to share information to our members as it becomes available.   

Monday the 1st of September 2025, ECHA published the CLH reports for the substances listed below in Table 1. Consequently, the Public Consultation is now open and spans 60 days, during which stakeholders are invited to provide comments on the hazard classes proposed in the CLH report. The CLH reports submitted by the Norwegian Environment Agency will undergo an evaluation by the Risk Assessment Committee of the ECHA over the next 12 months. The CLH reports can be found here.
Please also see our previous joint public communication: HARRPA_H4R_PCA_Rosin_DU_comm_20241114
The H4R Consortium and PCA are reviewing the CLH reports for Harmonised Classification and Labelling and intend to submit documents during the public consultation. The submitted documents will include:
- all relevant scientific information on the toxicity to reproduction (or lack thereof) of Rosins and derivatives,
- the outcome of the two new investigative studies sponsored by H4R and PCA, which provide evidence to support our position that none of these substances raise concern for reprotoxicity hazard and therefore do not meet the criteria for classification.
During public consultation, all stakeholders are invited to provide relevant information, including:
- Toxicological data, such as information on the intrinsic toxicological properties of rosin and rosin derivatives and/or mechanistic studies.
- information about the use of the substance, including its essentiality and critical technical function in your applications, exposure conditions and risk management measures currently in place.
Should you possess such data, we advise to contact the H4R consortium secretariat. The secretariat is equipped to provide comprehensive support throughout the submission process, ensuring that your valuable information is integrated into the consortium's assessments.
Further information is being generated and an updated communication will follow once the CLH reports have been reviewed.
An online Webinar will be organized on the 14th October, 15:00 CET to provide your organization with status, next steps and guidance on the public consultation phase. More information will follow once it becomes available. In case you have any questions or would like to share any information with us, please contact us at manager@h4rconsortium.com.
On behalf of the members of HARRPA, H4R Consortium, and PCA.
2024 November 14 Publication

In August 2023, ECHA published an Assessment of Regulatory Needs (ARN) document for Rosin and its derivatives. This ARN has subsequently led to a Harmonized Classification and Labelling (CLH) assessment on the substances by the Norwegian Environmental Protection Agency (the national Member State Competent Authority [MSCA] on REACH in Norway). Norway has registered its intentions to propose CLH for reprotox for 9 specific rosin and rosin derivative substances (8 managed by H4R Consortium). At the moment it is unclear what the basis is for the proposed CLH by Norway, especially since reprotox classification is not warranted based on the available scientific evidence on these substances.

PCA disagrees strongly with these proposed classifications, since, based on the available toxicological data, none of these substances raise any concern for reprotox hazard and therefore they do not meet the criteria for classification.

A formal PCA position paper is available, which provides the background necessary to understand the reasons for PCA’s position on this issue and is also intended to share some insights on the next possible steps. The paper can be downloaded here.

Note that PCA will update its stakeholders when significant developments occur and is willing to organize specific informative sessions to provide detailed information on any of the aspects of this case. For further inquiries, please reach out to office@pinechemicals.org.

office@pinechemicals.org.

The PCA is preparing to host a webinar on this issue for all stakeholders. Once the date and time are established, emails will be sent with those details.

Note that PCA will update its stakeholders when significant developments occur and is willing to organize specific informative sessions to provide detailed information on any of the aspects of this case. For further inquiries, please reach out to office@pinechemicals.org.

The PCA is preparing to host a webinar on this issue for all stakeholders. Once the date and time are established, emails will be sent with those details.

Note that PCA will update its stakeholders when significant developments occur and is willing to organize specific informative sessions to provide detailed information on any of the aspects of this case. For further inquiries, please reach out to office@pinechemicals.org.

The PCA is preparing to host a webinar on this issue for all stakeholders. Once the date and time are established, emails will be sent with those details.