Letters: December 2024

The article on the proposed classification of ethanol as reprotoxic raises questions again over outcomes of reviews under the EU classification, labelling and packaging (CLP) regulation 1272/2008 (see also the letter on its application to tea-tree oil).

The current proposal for the classification of ethanol has emerged from the biocides review programme, but a carcinogenic, mutagenic or reprotoxic (CMR) classification would have severe-to-catastrophic impacts on all uses of ethanol, from printing and cleaning through to cosmetics and sustainable fuels. Even the hospitality sector would be affected, because of the amount of health and safety legislation linked to the CLP regulation, even though alcoholic beverages themselves are exempt.

As pointed out, the problem arises because the classification system is hazard based. This would be OK if there were boundaries, which there are for all non-CMR hazards, such as acute toxicity, where there is a dose above which effects are not considered to warrant a hazard. This is not the case for the CMR end points where there is no such upper boundary with the result, in the case of ethanol, of epidemiology drinking studies being unscientifically extrapolated to infer hazards from completely different scenarios than those they assessed. The case of ethanol does bring into focus whether the criteria are fit for purpose having already ‘caught’ other high-profile substances such as titanium dioxide and silver.