Welcome to the H4R Consortium website

H4R, established in 2008 by the Cefic sector group HARRPA (H4R is HARRPA for REACH), represents the manufacturers of Hydrocarbon Resins, Rosin Resins and Pine Chemicals Materials for their REACH compliance activities, and is managed by Penman Consulting.

This website is intended to provide some general information on the consortium, and, amongst others, on the substances it manages with guidance on how to meet substance identity profile requirements and costs of letters of access for those substances.

Relevant (regulatory) developments will be communicated in the news section on this page.


News

September/October 2024


9 Rosin and Rosin Derivative substances have been included on ECHA’s Registry of CLH Intentions until Outcome (RoI)

As communicated below, in August 2023, ECHA published an Assessment of Regulatory Needs (ARN) document for Rosin and its derivatives. This ARN has subsequently led to a Harmonized Classification and Labelling (CLH) assessment on the substances by the Norwegian Environmental Protection Agency (the national Member State Competent Authority [MSCA] on REACH in Norway). Norway has registered its intentions to propose CLH for reprotox for 9 specific rosin and rosin derivative substances (8 managed by H4R Consortium). At the moment it is unclear what the basis is for the proposed CLH by Norway, especially since reprotox classification is not warranted based on the available scientific evidence on these substances.

H4R disagrees strongly with these proposed classifications, since, based on the available toxicological data, none of these substances raise any concern for reprotox hazard and therefore they do not meet the criteria for classification.

A formal H4R position paper is available, which provides the background necessary to understand the reasons for H4R’s position on this issue and is also intended to share some insights on the next possible steps. The paper can be downloaded here: 2024 11 14 HARRPA H4R PCA Rosin DU Comm.pdf

Note that H4R will update its stakeholders when significant developments occur and is willing to organize specific informative sessions to provide detailed information on any of the aspects of this case. For further inquiries, please reach out to manager@h4rconsortium.com.


August 2023


ECHA published an Assessment of Regulatory Needs (ARN) report on Resin and Rosin and its derivatives

The H4R Consortium notes that ECHA has recently published an Assessment of Regulatory Needs (ARN) document for Rosin and its derivatives. This document raises potential human health and environmental concerns and proposes that some substances might be possible candidates for harmonized classification due to toxicity to reproduction.

The H4R consortium disagrees strongly with the ECHA recommendation in the ARN report.

H4R would like to note that the Assessment of Regulatory Needs (ARN) is ECHA’s internal ad hoc informal screening process for prioritizing groups of substances – instead of single substances – for further evaluation. The ARN process is not regulated by REACH or any other European law, it does not constitute a final judgment of hazard or risk for human health or the environment. Instead, the stated aim is to stimulate MSCA to take the initiative and perform further evaluations to form their own independent views.

For Rosin and derivatives, a detailed analysis of all available data to conclude on the potential need for CLH, was initiated by the Norwegian MSCA. The H4R REACH Consortium has shared all relevant information with the Norwegian MSCA, including a complete reassessment of all relevant data and a Weight of Evidence (WoE) assessment describing why CLH is not warranted.

H4R has drafted a position paper which provides the background necessary to understand the reasons for H4R’s position on this issue and is also intended to share some insights on the next possible steps. The paper can be downloaded here: 2023 09 25 Rosin and Resins PR Paper Final.pdf

For further inquiries, please reach out to manager@h4rconsortium.com.


Disclaimer

This website is made available for public viewing on the basis that the H4R Consortium or Penman Consulting exclude to the extent lawfully permitted all liability whatsoever for any loss or damage arising out of use of this website. Further, whilst we endeavour to ensure the accuracy and completeness of the content of the pages of this website, the H4R Consortium and Penman Consulting do not accept any liability or responsibility for loss occasioned as a result of reliance placed on any part of its contents.