6 July 2026

Healthcare Professionals Handling Hazardous Medicinal Products Remain Unprotected as CMRD 6 Passes Without Annex I Inclusion

Every day, nurses, pharmacists and many other healthcare professionals across Europe are exposed to hazardous chemotherapy drugs and other hazardous medicinal products — substances classified as carcinogenic, mutagenic or reprotoxic — at work unnecessarily, with serious health consequences. Unfortunately, this is simply because they do not have the binding legal protections that would compel their employers to keep them safe.

The CMRD 6 trilogue, concluded on 23 June 2026, was an opportunity to change that by including HMPs in Annex 1 of the directive, a simple but effective amendment. But this did not happen.

The Stop Cancer at Work campaign, represented by the European Biosafety Network (EBN), the European Federation of Nurses Associations (EFN) and the European Federation of Public Service Unions (EPSU) is deeply disappointed that the trilogue did not deliver binding legal protection for healthcare professionals exposed to hazardous medicinal products (HMPs).

Hazardous medicinal products, including many chemotherapy drugs, are classified as carcinogenic, mutagenic or reprotoxic substances. In the healthcare sector alone, 12.7 million professionals across the EU are potentially exposed to HMPs. Despite this, HMPs do not appear in the core operative provisions of the EU’s Carcinogens, Mutagens and Reprotoxic Substances Directive.

Ahead of the political trilogue meeting, our organisations wrote jointly to the European Commission urging it to support three amendments to the CMRD 6 compromise text proposed by the European Parliament:

  1. The inclusion of work involving exposure to HMPs in Annex I of the Directive
  2. A formal legal definition of hazardous medicinal products within EU occupational safety law
  3. Reinforced training obligations for professionals exposed to HMPs

Without an explicit Annex I entry, employers across Member States cannot look at the legal text and identify a clear obligation to protect healthcare professionals who handle these substances. Some will miss HMPs entirely; others will use their absence from the legal text as justification for inaction. The result is a persistent and documented implementation gap one that leaves hundreds of thousands of healthcare professionals across Europe inadequately protected. All three amendments matter, but Annex I inclusion is the most important.

Additionally, the wording “work involving exposure to HMPs” brings the preparation, administration and disposal of these products within scope, not just the substances themselves. Employers must assess and manage the practices through which workers are exposed. That is a stronger and more protective obligation than anything a definition or recital can deliver.

Recital 12h, the training recital included in the final text, is a step forward. It confirms that EU legislative institutions formally recognise HMP exposure as requiring specific worker training and guidance. But a recital is not enforceable. National authorities cannot compel employers to act on the basis of interpretive language alone, and workers cannot rely on it to assert a legal entitlement.

The two substantive amendments — Annex I inclusion and a binding legal definition — were not retained. The implementation gap has not been closed.

The legislative history of HMPs points clearly in one direction: from EU guidance on HMP handling, to a formal definition, to an indicative list, to the training recital now included in CMRD 6. The Commission has, through its own February 2025 indicative list of HMPs, formally acknowledged that these substances pose a specific occupational risk. Annex I inclusion is the logical and necessary next step and it is long overdue.

We call on the European Commission to commit to the inclusion of work involving exposure to HMPs in Annex I of the CMRD as a stated priority in the CMRD 7 revision process, and to engage with our organisations and the broader healthcare worker community from the earliest stages of that process, including at the stakeholder consultation phase where the scope and direction of any revision is shaped.

Healthcare professionals across Europe cannot wait for another revision cycle. The legal framework must catch up with what the evidence has long made clear.

The Stop Cancer at Work campaign advocates for binding EU legislation to protect healthcare workers from occupational exposure to hazardous medicinal products. For more information: www.stopcanceratwork.eu