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OCTOBER 2025 I PCB007 MAGAZINE 35 and Restriction of Chemicals (REACH) point-of-view and a European Sustainability Reporting Standards (ESRS) point of view demonstrates these difficulties. • REACH is a comprehensive EU regulation that went into effect on June 1, 2007, and applies to all chemical substances, whether used in industrial processes or in everyday products such as paints, cleaning agents, clothing, furniture, and electronics. • ESRS is mandatory reporting guideline devel- oped under the CSRD, which aims to stan- dardize how companies disclose their ESG impacts and risks across the EU. Unlike REACH, which focuses on regulatory com- pliance, ESRS emphasizes sustainability impact and stakeholder relevance. This means companies may need to report on SVHCs even if they remain below the REACH thresholds, provided they are material. SVHCs represent a subgroup of Substances of Con- cern (SoC) with the most serious negative effects on the environment, health, and wildlife, as identified in Article 59(1) of Regulation (EC) 1907/2006 (REACH). Consequently, the definitions of SVHC and SoC are based on REACH, which also holds true for ESRS. Before reporting under ESRS, AT&S followed the Global Harmonization System (GHS) and reported the GHS hazard classes (health-related, environmen- tal, and physical) by applying these nine categories: 1. Explosive 2. Oxidizing 3. Highly flammable 4. Harmful to health 5. Toxic 6. Corrosive 7. Irritant 8. Dangerous to the environment 9. Other hazardous properties The ESRS requirement primarily refers to health- related and environmental hazard classifications. Physical hazards remain relevant (e.g., for occupa- tional health and safety and safety datasheets), but are not explicitly required under ESRS. With ESRS, the hazard categories for SVHS and SoC are classified in Annex VI, Part 3 of Regulation (EC) 1272/2008 of the European Parliament and of the Council: • Carcinogenicity, categories 1 and 2 • Germ cell mutagenicity, categories 1 and 2 • Reproductive toxicity, categories 1 and 2 • Endocrine disruption with effects on human health • Endocrine disruption with effects on the environment • Persistent, mobile, and toxic properties or very persistent, very mobile properties • Persistent, bioaccumulative and toxic proper- ties or very persistent and very bioaccumula- tive properties • Respiratory sensitization, category 1 • Skin sensitization, category 1 • Chronic aquatic toxicity, categories 1 to 4 • Hazardous to the ozone layer • Specific target organ toxicity (repeated expo- sure), categories 1 and 2 • Specific target organ toxicity (single expo- sure), categories 1 and 2 The conclusion is that even if the definition of a technical term is the same in reporting language, one cannot assume its classification remains the same across reporting systems.