An ESPR category for substances that are hazardous or can negatively affect reuse, recycling, and product circularity.
Substance of concern in ESPR is a broad regulatory category covering not just classic hazardous substances but also substances that can undermine reuse or recycling. It links chemical composition with circularity and product-information duties because a substance can matter through risk, reuse friction, recycling interference, or passport disclosure requirements.
Do not reduce substance of concern to only classic hazardous substances, and do not treat the label as a full risk assessment. The practical boundary is whether the substance triggers concern for safety, environment, reuse, recycling, or circularity.
The ESPR category is broader than a simple hazardous-substance label. It can include chemical risk and substances that affect reuse or recycling, which is why it matters for product information requirements and passports.
Represent substance records with identity, location in the product, threshold or reporting basis, source requirement, and relevance to reuse/recycling or other lifecycle outcomes.
Regulation (EU) 2024/1781 establishing a framework for the setting of ecodesign requirements for sustainable products
a substance that: (a) meets the criteria laid down in Article 57 of Regulation (EC) No 1907/2006 and is identified in accordance with Article 59(1) of that Regulation; (b) is classified in Part 3 of Annex VI to Regulation (EC) No 1272/2008 in one of the following hazard classes or hazard categories: (i) carcinogenicity categories 1 and 2; (ii) germ cell mutagenicity categories 1 and 2; (iii) reproductive toxicity categories 1 and 2; (iv) endocrine disruption for human health categories 1 and 2; (v) endocrine disruption for the environment categories 1 and 2; (vi) persistent, mobile and toxic or very persistent, very mobile properties; (vii) persistent, bioaccumulative and toxic or very persistent, very bioaccumulative properties; (viii) respiratory sensitisation category 1; (ix) skin sensitisation category 1; (x) hazardous to the aquatic environment — categories chronic 1 to 4; (xi) hazardous to the ozone layer; (xii) specific target organ toxicity — repeated exposure categories 1 and 2; (xiii) specific target organ toxicity — single exposure categories 1 and 2; (c) is regulated under Regulation (EU) 2019/1021; or (d) negatively affects the reuse and recycling of materials in the product in which it is present;
Reference: Article 2, point 27
Reviewed public draft page. Aligns with environmental/footprint policy: separates lifecycle boundaries, impact categories, carbon values, gas inputs, durability evidence, post-use events, and composition/circularity controls.
Implementation records should capture composition record, substance identifier, hazard or circularity flag, DPP field, material location, concentration or threshold, regulatory source, supplier evidence, reuse/recycling implication, and disclosure/access rule.
Substance of concern is the composition-to-circularity control for product data. It should link material composition, chemical risk, circularity friction, passport fields, and disclosure rules without treating every material attribute as the same kind of compliance claim.