Kapitel 1: Umwelt-Mindestkriterien

Kategorie: Chemicals

Chemicals harmful to the environment (E38)

Criteria question

[no modifications]

Does the standard include criteria on H statements H400, H410, H411?


Refers to chemicals classified as environmental hazards statements according to GHS (Globally Harmonized System of Classification and Labelling of Chemicals). The lowest degree of intensity also recognizes approaches assessing the substances in use taking into account aquatic toxicity via the PEC/PNEC ratio.

Degree of Intensity (DoI)

[no modifications]

  1. Prohibit use for some applications
  2. Prohibit use for all applications
  3. Prohibit use of additional H statements for all applications


We suggest that approaches that evaluate the substances on the basis of a PEC/PNEC approach and set a list of substances that may be used, are considered as equivalent to the lowest degree of intensity. This should be reflected in the guidance note.

Degree of Intensity:
The following alteration to the degree of intensity is proposed; the minimum criterion relates to the lowest degree of intensity

This criterion is currently a minimum criterion.

Kommentare (2)


ID: 24 12.10.2018 08:34

Does this point only cover H400, H410 and H411? Why are there additional H-statements mentioned? Which statements should be covered?


Kommentar der Moderation
ID: 49 16.10.2018 10:25

To meet the minimum requirements, a standard should include criteria on the prohibition of chemicals harmful to the environment, at least for those with an H-statement H400, 410, 411. Alternatively, a PEC/PNEC approach with a white-list of chemicals would be sufficient.