- CropLife Europe wishes to caution that the rushed adoption of the PMT criteria may result in a regulation not fit for purpose. As the newly introduced hazard classes will be referred to across the regulatory landscape, a clear understanding of the practical consequences affecting all types of chemicals in scope of CLP Regulation is necessary prior to a legislation proposal being introduced.
- Leachability defined as percentage of a chemical that can reach drinking water sources represents the best parameter to define the mobility criterion (M). Croplife Europe proposes categorisation based on the M criterion:
o Confirmed PMT (Category 1) based on leachability
o Suspected PMT (Category 2) based on KOC
P and T criteria would remain unchanged (i.e., confirmed only).
3. CLE does not support a separate hazard class for vPvM nor the expansion of the T criterion to terrestrial toxicity due to lack of sufficient scientific evidence.