Skip to main content

CLE Input on PMT Criteria in response to CARACAL Meeting

Description





  1. 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.

  2. 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.