Aligning and simplifying chemical, industrial emission and water quality regulations: Towards a coherent EU framework for persistent, mobile and toxic (PMT) and very persistent, very mobile (vPvM) substances

Abstract Background : Persistent, mobile and toxic (PMT) and very persistent and very mobile (vPvM) substances threaten water resources when released in large volumes because they persist in the environment, spread readily through aquatic systems, and are difficult to remove once contamination has occurred. The introduction of the PMT and vPvM hazard classes under the Classification, Labelling and Packaging (CLP) Regulation represents an important step toward identifying PMT/vPvM substances, but effective environmental protection requires consistent regulatory advancements and alignments across related EU chemicals legislation to include these hazard classes. This paper examines how the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) Regulation, the Industrial Emissions Directive (IED), and the Water Framework Directive (WFD) currently regulate PMT/vPvM substances and identifies opportunities to strengthen the coherence of these legislative frameworks to protect water resources. Results : The analysis shows that the current regulatory framework remains fragmented. Under REACH, PMT/vPvM substances can only be identified systematically through the resource-intensive equivalent level of concern clause, delaying risk management measures. Under the IED, emissions control largely depends on regulatory pathways established under REACH and the WFD. The WFD relies on monitoring data and established risk assessments that often fail to capture PMT/vPvM substances before widespread contamination occurs. The paper shows that systematically integrating the new CLP hazard classes into REACH, the IED, and the WFD would strengthen and simplify the links between hazard identification, chemicals management, industrial emissions control, and water protection. Conclusion: Consistent implementation of the new CLP hazard classes in REACH, the IED, and the WFD would create a more coherent, simpler and preventive framework for minimizing emissions of PMT/vPvM substances to the environment. This would strengthen the EU's ability to prevent long-term contamination of water resources while supporting the objectives of the European Green Deal and the Zero Pollution Action Plan.