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If You Manufacture or Import Chemicals in the EU — It’s Time to Double-Check Your Portfolio
The European Chemicals Agency (ECHA) just dropped its 2025–2027 Community Rolling Action Plan (CoRAP) — and 28 substances are now on the radar for regulatory scrutiny under Articles 44–48 of EU REACH Regulation (EC No 1907/2006).
This isn’t just another list. It’s a forward-looking blueprint for which substances may face further data requirements, restrictions, or even SVHC designation. And if your product uses any of these substances, even unintentionally, you're already in scope.
What Is CoRAP and Why Should You Care?
CoRAP is ECHA’s formal Substance Evaluation program, designed to assess whether a chemical poses an unacceptable risk to human health or the environment.
Substances evaluated under CoRAP:
- May result in data requests or follow-up regulatory actions
- Are investigated by Member State authorities
- Can lead to classification as SVHCs or inclusion in the Restriction/Authorisation lists
So, if your product contains a CoRAP-listed substance, you’re not in the clear. You could be facing stricter controls, testing demands, or market bans down the line.
What’s New in the 2025–2027 CoRAP Plan?
- 13 New Substances Added
These chemicals were prioritized based on:
- Carcinogenic, mutagenic, reproductive toxicity (CMR)
- Endocrine-disrupting potential
- Widespread consumer and occupational exposure
- PMT/vPvM properties (Persistent, Mobile, Toxic)
Examples include:
- Tris(2-ethylhexyl) phosphate (78-42-2): Suspected carcinogen and endocrine disruptor
- Triethyl phosphate (78-40-0): High tonnage, suspected reproductive toxicity
- Potassium dicyanoargentate (506-61-6): Strong environmental and human health risk signals
- 18 Substances Carried Over
These were already under scrutiny in the 2024–2026 CoRAP and remain under evaluation, pending further dossier updates or supplementary data.
2025–2027 CoRAP Plan Evaluation Timeline Breakdown
Withdrawn Substances — But Not Without Consequences
Three substances were pulled from the plan, but that doesn’t mean they’re off the hook:
- Benzaldehyde (100-52-7): Existing data addressed concerns
- Sodium hydroxymethanesulphinate (149-44-0): Additional data requested; may reappear
- Triphenylthiophosphate reaction mass: Now officially classified as a Substance of Very High Concern (SVHC) and moving to stricter regulation
The Silent Risk: Benzotriazole Derivatives and PMT/vPvM
A recurring theme in the 2026 list is benzotriazole-based UV stabilizers — many of which are:
- Persistent (don’t degrade easily)
- Mobile (can contaminate groundwater)
- Toxic (harm aquatic and human health)
This includes complex mixtures and reaction masses, such as:
- C7–C9 alkyl benzotriazolyl propionates
- Poly(oxyethylene)-linked benzotriazole derivatives
They’re used across plastic coatings, electronics, and consumer goods, meaning you might not even know you’re using them unless your BOM screening is structured and up-to-date.
What Should Compliance Teams Do Now?
If you wait for ECHA to reach out, it’s already too late.
- Screen your BOMs and chemical dossiers against the latest CoRAP list
- Use structured formats like IPC-1752A or IEC 62474 for supplier data exchange
- Engage your suppliers — especially for substances flagged as PMT/vPvM
- Be prepared for follow-up evaluation decisions, including SVHC proposals
- Document your due diligence efforts to stay audit-ready
Related Blogs You Might Find Useful:
- Understanding REACH Lists: SVHC vs Annex XIV vs Annex XVII
- REACH Recast Is Coming: Here's What Changes
Final Word
CoRAP isn’t just another chemical list, it’s an early warning system. If your substances are on it, you need to **act, document, and stay ahead of REACH enforcement**. Because once the evaluations are complete, the consequences won’t be optional.