Epichlorohydrin (ECH, 1-chloro-2,3-epoxypropane; CAS 106-89-8; EC 203-439-8; CN code 2910 30 00) enters the EU as a bulk liquid intermediate for epoxy resin synthesis, epichlorohydrin elastomer production, and wet-strength resin chemistry. Under the harmonised classification in Annex VI Part 3 of Regulation (EC) No 1272/2008 (CLP), index number 603-026-00-6, ECH is Flam. Liq. 3, Acute Tox. 3 by inhalation and dermal routes, Acute Tox. 4 by oral route, Skin Corr. 1B, Skin Sens. 1, and Carc. 1B. The Carc. 1B classification triggers REACH Annex XVII entry 28, which prohibits supply to the general public at or above the CLP generic concentration limit for Carc. 1B of 0.1% w/w. The same endpoint places ECH on the ECHA Candidate List as a substance of very high concern under Article 57(a) of REACH. Importers are therefore subject to three interlocking regimes: pre-market REACH registration under Article 6, CLP labelling and safety data sheet harmonisation under Annex II of REACH as amended by Regulation (EU) 2020/878, and the 2026 transitional dates under Regulation (EU) 2024/2865 and Commission Delegated Regulation (EU) 2023/707.

Does Annex XVII Entry 28 Prohibit Bulk ECH Imports?

Annex XVII entry 28 is not an import ban; it is a supply restriction. Because ECH is classified as Carc. 1B in Part 3 of Annex VI to CLP, a substance or mixture containing ECH at a concentration equal to or greater than the CLP generic concentration limit of 0.1% w/w shall not be placed on the market, or used, as a substance, as a constituent of other substances, or in a mixture for supply to the general public. The restriction is subject to derogations for medicinal products, veterinary medicinal products, cosmetic products, and food or feeding stuffs under their specific EU legal frameworks. Industrial and professional supply remains permitted provided the recipient is not a consumer and the label communicates the harmonised hazard set without dilution. A technical-grade ECH shipment at ≥99.5% w/w purity exceeds the 0.1% w/w threshold; therefore direct sale to private consumers, including distance sales fulfilled to a private EU address, is prohibited.

Downstream users receiving ECH for closed-process epoxy resin synthesis should document that the use is not a supply to the general public and that the substance is handled as an intermediate where applicable. If the imported ECH is consumed under strictly controlled conditions as an intermediate, reduced registration requirements under Article 17 of REACH may be available, but the Annex XVII entry 28 restriction still applies to any residual mixture containing ECH above 0.1% w/w that is placed on the market for general consumers. The harmonised Carc. 1B classification also activates the workplace requirements of Directive 2004/37/EC on carcinogens, mutagens and reprotoxic substances. An importer blending or repacking ECH must provide an extended safety data sheet and label to downstream workplaces in the official language of the destination Member State.

During bulk unloading of ECH from UN 2023 tank containers, Class 6.1, Packing Group II, subsidiary hazard 3, closed-loop vapour return and dry-break couplings reduce atmospheric release of the epoxide-reactive liquid. The ACGIH TLV-TWA of 0.5 ppm (1.9 mg/m³) with skin notation is a recognised industrial hygiene benchmark; EU Member State occupational exposure limits may be lower and take precedence. ECH flammability classification requires bonding and grounding during transfer, and stored liquid should be kept under nitrogen blanket to control moisture ingress and colour development. Published data on long-term carbon steel storage of high-purity ECH is limited; stainless steel tanks or lined carbon steel are therefore used where iron contamination must be avoided in downstream epoxy resin catalyst systems.

When the 2026 CLP Transitional Dates Reach ECH Labels and Safety Data Sheets

The main CLP revision applies from 1 July 2026 under Regulation (EU) 2024/2865. Importers must update label readability and hazard communication elements where required by the revised provisions. Separately, Commission Delegated Regulation (EU) 2023/707 added new CLP hazard classes for endocrine disruption, persistent, bioaccumulative and toxic or very persistent and very bioaccumulative properties, and persistent, mobile and toxic or very persistent and very mobile properties. For substances already on the EU market, such as ECH, the compliance deadline for reclassification and SDS/label updates for those new classes is 1 November 2026. ECH does not currently carry a harmonised entry under those new classes, but the importer must maintain a documented self-classification screening for the new endpoints. If new test data trigger classification, the label, SDS, and C&L notification would need to be updated by the 1 November 2026 transitional deadline.

An importer that has not completed a new-endpoint screening should not treat the 2026 date as a postponement of existing CLP duties. Harmonised classification, labelling, and packaging obligations under CLP apply from the first placing on the EU market. The 2026 deadline is therefore a compliance review point, not an initial classification trigger. For ECH importers, the practical control is a regulatory information management record showing that each new hazard class was assessed against available toxicological and fate data, and that the harmonised Carc. 1B entry remains the governing classification unless the screening conclusion is revised.

Separate from REACH registration and CLP reclassification, importers of ECH-containing mixtures must maintain Annex VIII poison centre notifications under Article 45 of CLP. For mixtures assigned to industrial uses only, the deadline was 1 January 2025; for consumer and professional uses the deadline was 1 January 2021. Each mixture requires a unique formula identifier in the PCN file and on the label. No 2026-specific PCN deadline replaced these duties; the 2026 dates concern CLP revision and new hazard class transition. C&L notifications under Article 40 of CLP are rolling requirements that follow first placement on the EU market, not the 2026 calendar.

Epichlorohydrin Import Compliance Checklist and CLP Harmonised Entry

The harmonised CLP entry under index number 603-026-00-6 contains Flam. Liq. 3 H226; Acute Tox. 3 H331 by inhalation; Acute Tox. 3 H311 by dermal exposure; Acute Tox. 4 H302 by oral intake; Skin Corr. 1B H314; Skin Sens. 1 H317; and Carc. 1B H350. The IARC Monographs Volume 71 Group 2A designation supports the carcinogen endpoint. For mixture classification, the generic concentration limit for Carc. 1B is 0.1% w/w; Skin Sens. 1 H317 also uses the generic 0.1% w/w concentration limit in the absence of a lower harmonised SCL. These concentration limits are the operational trigger for Annex XVII entry 28 and for extended safety data sheet obligations under Article 31.

At the point of entry, ECH is declared under CN code 2910 30 00, and the transport document shows UN 2023, Class 6.1, Packing Group II, subsidiary hazard 3. Import documents should contain the safety data sheet in the official language of the Member State of destination under Article 31(5) of REACH. Where the receiving site is in Germany, for instance, a German-language SDS is required; an English-only SDS is not sufficient for compliance. The 2026 CLP label transition does not alter the ADR transport classification or the customs declaration field for CN code 2910 30 00.

Where ECH is converted into liquid epoxy resin and subsequently cured in an article, Article 33 of REACH applies only if the article contains ECH as an SVHC above 0.1% w/w. Published data on residual unreacted ECH in cured epoxy articles is formulation-dependent and cure-cycle dependent; a generic migration or concentration assumption is not valid. The importer that places the substance into the EU market must therefore retain batch-level documentation tying the SVHC communication duty to the specific downstream article, and must not rely on the 2026 label transition as a substitute for that article-level assessment.