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UBA
The UBA list PMTvPvM substances REACH
Protecting the aquatic environment from chemicals for future generations: The UBA list of 259 PMT/vPvM substances (based on the new CLP criteria) in the REACH Regulation concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals registration database that are hazardous to our drinking water resources and must not be emitted into the environment. Registrants and downstream users (DSUs) can act immediately to minimise emissions throughout the life cycle of these substances of very high concern (SVHC) to protect the aquatic environment for future generations.
In the evolving landscape of European chemical regulation, staying compliant means keeping pace with new categories and risk assessments. One emerging focus area is the UBA list of PMT/vPvM substances under the REACH framework — a crucial development for companies striving for advanced chemical compliance.
These Persistent, Mobile, and Toxic (PMT) or very Persistent and very Mobile (vPvM) substances pose unique environmental challenges. Unlike classic persistent organic pollutants, PMT/vPvM substances can spread rapidly through water systems, making their containment and management even more complex.
This article explores what the UBA list entails, why it matters for your regulatory obligations, and how to adapt your safety data sheet processes to stay compliant.
The German Environment Agency (UBA) has been instrumental in defining PMT and vPvM substances to fill regulatory gaps left by traditional criteria like PBT (Persistent, Bioaccumulative, Toxic). While PBT substances are well known, PMT/vPvM compounds pose a distinct risk because they persist in the environment and travel easily through aquatic pathways, contaminating drinking water and ecosystems.
Under REACH, these substances demand closer scrutiny. Companies must identify them in their portfolios, evaluate exposure scenarios, and communicate risks more transparently in every safety data sheet they produce.
Inclusion on the UBA list is more than a scientific classification — it is a signal for regulators, industry, and the public that stricter controls are coming. For advanced chemical compliance, this means:
Failing to act early could expose companies to non-compliance risks, reputational damage, and potential restrictions on their products in the EU market.
Experts agree that the best approach combines technical rigour with strategic foresight. Start by integrating PMT/vPvM assessments into your chemical management systems. Revise your hazard and exposure data to reflect mobility factors, not just persistence or toxicity.
Invest in upgrading your safety data sheet workflows to ensure these substances are properly flagged and described. Work closely with suppliers and customers to track use patterns, emissions, and downstream impacts.
Finally, keep an eye on future updates. The UBA continues to expand its list, and the European Chemicals Agency (ECHA) is actively considering how to integrate these criteria more formally into REACH restrictions and authorisations.
As regulators place greater emphasis on water protection and environmental mobility, PMT/vPvM substances represent the next frontier for forward-thinking chemical companies. Staying ahead will require more than ticking boxes — it demands real collaboration, transparency, and investment in safer alternatives.
For businesses that act now, this is a chance to lead rather than react. Build your expertise, strengthen your safety data sheet documentation, and position your brand as an industry leader in sustainable chemical compliance.
The UBA list of PMT/vPvM substances is a clear reminder that environmental stewardship and compliance are evolving together. By understanding these substances and taking early action, you can protect your market access, reduce environmental risks, and demonstrate real commitment to responsible chemical management.
Ready to future-proof your compliance processes? Connect with our expert team today and ensure your safety data sheets and substance portfolios meet the highest standards.
