A regulatory term referring to a substance that: (a) meets the criteria laid down in Article 57 of Regulation (EC) No 1907/2006 and is identified in ac.
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. The category therefore links chemical risk and circularity friction inside one disclosure-relevant concept.
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
This term matters when companies map product composition to disclosure, ecodesign, and circularity obligations, especially where material recovery is affected by the substance profile. It also affects what downstream actors need to know to handle products safely and recover materials effectively.
For Minespider, substance of concern is a composition-to-circularity term. It shows how ingredient-level product data can shape not only safety obligations but also whether reuse and recycling pathways remain commercially and operationally viable.