▪︎ CLP
For the First Time, the Risk Assessment Committee (RAC) Greenlights Classification of a Substance as Very Persistent and Very Bioaccumulative
The members of the ECHA RAC committee agree with the German proposal to classify the substance 4,4'-methylenebis(dibutyldithiocarbamate) as very persistent and very bioaccumulative (vPvB). The CLP revision in 2023 created this new hazard class which now finds its first application.
RAC officials greenlit the classification at their meeting in December 2025.
Classification and arguments
“Very bioaccumulative” means that the substance is passed on through the food chain and can accumulate in organisms. Nutritional studies on fish have demonstrated this finding. The experts also based their decision on a qualitative assessment of the available data. The substance persists for long periods of time after adsorption to soil or sediments.
“Very persistent” means that the substance degrades very slowly in the environment. Its chemically stable dithiocarbamate structure, high molecular weight, and low water solubility cause this level of persistence.
It’s not about the mass
Although the substance is not a high-volume chemical and used industrially only in niche applications, such as in oils, lubricants, and greases, its use must be regulated. Its persistence in even small emissions can be harmful to the environment. Potential entry routes include leaks and improper disposal of waste oil.
The ECHA is expected to publish the RAC’s detailed opinion in the coming months.
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