Decisions of the RAC and public consultation on the revision of the classification of hydrochloric acid
From the ECHA public consultation to the recent opinions of the RAC: possible significant changes for the classification, labelling and management of mixtures containing hydrochloric acid and other harmonised substances
07 Apr 2026It is open until 18 May 2026 the ECHA public consultation on the proposed modification of the harmonised classification and labelling (CLH) of hydrochloric acid in solution, presented by Latvia pursuant to regulation CLP (Reg. (EC) No. 1272/2008).
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Current harmonisation |
Latvian harmonisation proposal |
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Skin Corr. 1B, H314, |
Met. Corr. 1, H290, |
Key points of the proposal
- Elimination of specific concentration limits (SCL) for skin and eye corrosion
- Introduction of corrosivity for metals
- Introduction of acute oral and inhalation toxicity, based on experimental data and clinical cases, with distinct ATE for ingestion, vapours and aerosols.
- Overcoming of STOT SE 3: the effects on the respiratory system are attributable to local corrosive lesions , more correctly covered by H314/H318 and EUH071.
During the March 2026 meetings, the Risk Assessment Committee (RAC) adopted 11 opinions on harmonised classification and labelling (CLH) pursuant to the CLP regulation:
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Substance |
RAC Decision |
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N,N‑dicyclohexylbenzothiazole‑2‑sulphenamide (DCBS) |
Agreement on the German proposal for vPvB classification with assignment of EUH441 (persistent environmental accumulation) |
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Reaction products of ammonium bromide and sodium hypochlorite (BAC, generated in situ) |
Repr. 1B (H360FD), Lact. (H362) and Aquatic Chronic 2 (H411), in line with the Swedish proposal |
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Tonalide (naphthyl ethanone) |
Repr. 1B (H360Df), STOT RE 2 (H373 – thyroid), Aquatic Acute 1 (H400) and Aquatic Chronic 1 (H410) |
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MEKO‑releasing silanes and butanone oxime (MEKO) |
Carc. 1B (H350), STOT SE 1 (H370), STOT RE 2 (H373 – haematological system) and Skin Sens. 1 (H317) |
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Potassium bromate |
Addition of Muta. 2 (H341) and STOT SE 1 (H370 – kidney and auditory organs); revised oral ATE 160 mg/kg bw |
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Sodium bromate |
Acute Tox. 3 (H301), Muta. 2 (H341), Carc. 1B (H350) and STOT SE 1 (H370 – kidney and hearing); oral ATE 140 mg/kg bw |
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Trimagnesium diphosphide / magnesium phosphide |
Confirmation of Acute Tox. 1–2 and revision of ATE values (oral, dermal and inhalation) |
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Aluminium phosphide |
Acute Tox. 1 (H300) with oral ATE 4 mg/kg bw, inhalation ATE 0.03 mg/L, dermal ATE 30 mg/kg bw |
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Cannabidiol (CBD) |
Repr. 1B (H360FD) and Lact. (H362), as proposed by France |
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Cinnamaldehyde (cinnamal) |
Maintenance of Skin Sens. 1A (H317) and addition of Acute Tox. 4 (H302, H312), Skin Irrit. 2 (H315), Eye Irrit. 2 (H319) and Aquatic Acute 1 / Chronic 2 |
The revision of the classification and labelling of hydrochloric acid and the new RAC opinions indicate important regulatory changes, with possible reclassifications that will directly impact products, labels and risk assessments. There is a growing focus on protecting health and the environment.
Companies are recommended to monitor regulatory developments and promptly plan the necessary adjustments.