Sometimes, the simplest answers take the longest to get confirmed.
At BENS Consulting, we’ve been consistently treating carriers – like cellulose fibers in nicotine pouches or the plastic body of car air fresheners – as outside the scope of classification under CLP.
And now, ECHA has confirmed exactly that.
The background
Nicotine pouches are made of cellulose fibers (basically a pouch material) that are impregnated with nicotine, water, sweeteners, and flavorings. The same type of question arises with car air fresheners: a plastic carrier that slowly releases fragrance.
It should be noted that nicotine pouches are not considered as chemical products in all EU Member States, and coordination is currently ongoing among Member States regarding their labeling. Furthermore, there are ongoing discussions indicating that nicotine pouches may in the future be regulated under a separate, dedicated regulatory framework, which could provide greater clarity and harmonization across the EU market.
For years, the question has been:
Should these carriers (cellulose or plastic) be counted as part of the mixture when calculating concentrations for classification?
The question we asked
We asked ECHA directly:
- Do cellulose fibers in nicotine pouches count as part of the mixture?
- Or should only the impregnating liquid (nicotine + additives + water) be considered?
- And is it the same principle for air fresheners – the fragrance is classified, but not the plastic body?
The official answer from ECHA
ECHA’s Regulatory Support Team confirmed what we had been applying in practice:
“For the classification, indeed you need to classify the impregnating mixture in both cases, not taking the carrier material into account.”
In plain terms: the cellulose pouch is just a carrier. Same with the plastic body of an air freshener. You classify only the substances that are released – not the inert material that holds them.
Why this matters
- Clarity for companies: If you’re producing or placing nicotine pouches or similar products on the EU market, you can stop worrying whether to include the carrier.
- Consistency across products: This principle doesn’t just apply to nicotine pouches. Any product where an inert carrier simply delivers a chemical mixture follows the same logic.
- Regulatory alignment: ECHA’s confirmation aligns national helpdesk interpretations and gives industry a clear basis for compliance.
Final note
As always, remember: ECHA’s guidance helps with interpretation, but the legal text of the CLP Regulation remains the only authentic reference.
Still, this is an important confirmation that brings much-needed clarity for companies working with products like nicotine pouches and air fresheners.
Let me know if this was helpful. And you’re welcome to contact me at anze.kriz@bens-consulting.eu if you need help navigating through the chemical compliance jungle.
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