Request to RAC to review the RAC opinion in relation to the harmonised classification of lead

On 30 November 2018, RAC adopted an opinion on the harmonised classification and labelling of lead. The dossier submitter (Denmark) had proposed a classification for environment, for both the massive and the powder form, as Aquatic acute 1 and Aquatic chronic 1, with M factors of 10. The RAC opinion confirmed the dossier submitter's proposal but with an Mfactor of 1 for Aquatic acute 1.

Following the adoption of the opinion, manufacturers of the substance provided new information on the chronic toxicity of lead in the pond snail Lymnea stagnalis (OECD 243). The new information may have an impact on the classification of lead as Lymnea stagnalis was considered as the most sensitive species for chronic toxicity on the basis of the available data when the RAC opinion was developed. In addition, the RAC opinion contains an appendix describing an alternative view, ultimately not supported by RAC, for the classification of lead with a particle diameter ≥ 1 mm (i.e., lead in massive form). During the decision making process, including the consultation of the Commission expert group (i.e., CARACAL) and taking into account the arguments provided in the alternative view, some concerns have been expressed with regard to the final decision of RAC not to have a split classification for the powder and the massive form of lead.

Consequently, the environmental classification of lead should be reviewed by RAC, in accordance with recital 5 (see below) of the draft Commission Regulation updating the entry of lead listed in Annex VI of Regulation (EC) No 1272/2008.

Link to the Request to RAC to review the RAC opinion in relation to the harmonised classification of lead