RAC recommended Category 1B for developmental effects (H360Df) alongside Category 2 for adverse effects on sexual function and fertility. It also upgraded the acute inhalation toxicity classification to Acute Tox. 3 (H331) with an ATE of 3 mg/L for vapours, from the previous Category 4.
The opinion was based on a harmonised classification and labelling proposal submitted by Germany in 2024 and evaluated during RAC's 77th plenary meeting. TFA is a terminal breakdown product of certain restricted PFAS precursors, which brings it into the scope of compliance discussions for tattoo inks and permanent make-up under REACH Annex XVII Entry 75.
Under REACH Article 57(c), substances classified as Repr. 1B automatically meet the criteria for identification as substances of very high concern. SVHC identification triggers candidate listing and potential authorisation prioritisation rather than an instant sales ban.
The classification is a hazard signal and does not itself impose a product ban or recall order. Companies using fluorinated precursors that can degrade to TFA should track the CLP amendment process and downstream authorisation developments.
