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Chemicals Coffee Time Monthly, April 2025

Posted
Updated
ByEmma

Dear Reader,

April has been another busy month in the chemical industry, so let’s dive straight into some of the changes.

Hearing from the HSE, DEFRA and the UK

Next batch of GB-CLP opinions published

You can download them as an .xls file from this webpage: https://www.hse.gov.uk/chemical-classification/classification/publication-template.htm?

I’m sorry that I haven’t had the energy to go through these in detail, but hopefully this will include more Mandatory Classification proposals which will align with some of the new Harmonised Classifications.

Using the CE mark in the UK

Alison Potts of WSP writes: On Tuesday 1st April the ‘Product Regulation and Metrology Bill’ had its Second Reading in Parliament (UK).Summary: On Tuesday (1st April) the ‘Product Regulation and Metrology Bill’ gets its Second Reading in Parliament (UK).Summary: https://commonslibrary.parliament.uk/research-briefings/cbp-10224/The bill: https://publications.parliament.uk/pa/bills/cbill/59-01/0201/240201.pdf. The supporting notes: https://bills.parliament.uk/publications/56104/documents/5029

It started off in the King’s Speech as the ‘Product Safety and Metrology Bill’ but it’s had a bit of an expansion in scope since then. The bit of most interest is really Clause 1(2). It will allow the secretary of state (by way of Statutory Instrument, rather than Parliamentary Bill) to introduce EU product law/legislation if it comes under ‘reducing or mitigating environmental impact’.

It is definitely intended to allow the CE mark to continue to be used in the UK (spelled out more clearly in the supporting notes) and other intended purposes of this bill include Toy Safety, E-bikes (batteries), and legislation around online market places. But this could potentially be the governments proposed short-term solution to sticking Northern Ireland/GB/EU together for a bit longer – forcing just enough alignment to allow EU products to be marketed and used in the EU.

Many thanks to Ali, it would certainly be helpful to continue to use the CE mark here.

New approach to regulations page updated

Nik Robinson of Nikam Consulting Ltd has spotted that the UK policy paper on “regulations to support growth” has been updated on 31st March, see: https://www.gov.uk/government/publications/a-new-approach-to-ensure-regulators-and-regulation-support-growth/new-approach-to-ensure-regulators-and-regulation-support-growth-html He adds: “There are a few nuggets in it re: chemical regulation, that may impact the future of UK REACH and wider UK chemical regulation:

“We will tackle instances where current approaches are unnecessarily limiting growth. This means working with regulators to identify specific opportunities where we can adapt practices whilst maintaining high-standards across our economy. This includes:

HSE and DEFRA consulting on how international approvals can be recognised to reduce the time and cost to bring chemical products, including biocides, to the GB market.”

“Defra will reduce UK REACH fees next month by an estimated £40m in total over the next six years, with the cost of registration expected to reduce for over 90% of firms”

“HSE and DEFRA will consult on how international approvals can be recognised to reduce the time and cost to bring chemical products, including biocides, to the GB market.”

It is certainly interesting, and I wonder if it might lead to some changes. Certainly the last bit fills me with both hope and concern, are we just going to take wholesale EU registrations or data packages? How? Conversely will this mean an influx of competition from non-UK companies that can now refer to the EU biocide dossier and compete with UK suppliers with out any of the previous data cost barriers?”

Many thanks to Nik for sending this excellent summary through. It will be interesting to see whether/ how this new approach converts into actions, and also whether there are any alterations after the forthcoming EU/GB negotiations in May.

EU/NI and GB relations

Harmonised and Mandatory Classification relationship

As the HSE remind us regularly, it’s really important for GB companies to comment on EU CLH proposals as well as EU and NI companies. This is because if GB-CLP reviews any EU Harmonised Classifications for the GB Mandatory Classification List, there is no further public consultation. Only Mandatory Classification Proposals which originate in GB have a GB public consultation.

It has been proposed to sever this link, but that will depend on the overall relationship between the two parties going forwards.

Negotiations on overall EU and UK relationship

There is a summit meeting on the 19th May, with more meetings planned, to go over this relationship, see https://www.politico.eu/article/eu-leaders-to-travel-to-uk-for-brexit-reset-summit-in-may/ . It is possible that chemical legislation may be in for some changes, another “watch this space” moment.

Keeping an Eye on ECHA and the EU

“New” EU-REACH proposals

We recently had the 54th meeting of CARACAL (the Member State Competent Authorities for chemicals), which included the proposal for the REACH recast.

There’s an excellent summary of what’s going on from Steven Brennan at Foresight, which you can find here: https://www.useforesight.io/news/reach-revision-2025-industry-pushback-intensifies-after-caracal-54-proposals.

And the full list of documents is here:https://circabc.europa.eu/ui/group/a0b483a2-4c05-4058-addf-2a4de71b9a98/library/6b969153-ce77-439c-9652-4228806798f0

Briefly, there’s nothing really new about these proposals, and a cynic might suggest that it brings back everything industry doesn’t want to see.

Despite being badged as a “simplification”, it’s so burdensome that even CEFIC (often seen as the voice of the larger chemical company) have complained about the burden https://cefic.org/media-corner/newsroom/cefic-statement-on-the-latest-reach-discussions-at-caracal/. I can’t remember if I’ve ever seen such a blunt statement from them.

There has been a consultation for CARACAL members about this which closed on 25th April, and we can only hope that CEFIC and other industry representatives manage to have these proposals modified.

Lots of proposed Harmonised Classifications…

Did you know there are 20 new EU HC proposals on the 8th April (including Peanut Butter); 11 on the 7th April; and 4 on the 1st of April?

8th April

  • Tetrasodium 4-amino-5-hydroxy-3,6-bis[[4-[[2-(sulphonatooxy)ethyl]sulphonyl]phenyl]azo]naphthalene-2,7-disulphonate, 17095-24-8
  • Sodium chlorite, 7758-19-2
  • resorcinol; 1,3-benzenediol, 108-46-3
  • peanut butter, (no CAS no)
  • hexythiazox (ISO); trans-5-(4-chlorophenyl)-N-cyclohexyl-4-methyl-2-oxo-3-thiazolidine-carboxamide, 78587-05-0
  • Formaldehyde, 50-00-0
  • D-tagatose, 87-81-0
  • cis-tricos-9-ene, 27519-02-4
  • Calcium acetylide, 75-20-7
  • Butyl 2,3-epoxypropyl ether, 06/08/2426
  • Bis(pentane-2,4-dionato)calcium, 19372-44-2
  • benzyl 4-amino-3-chloro-6-(4-chloro-2-fluoro-3-methoxyphenyl)-5-fluoropyridine-2-carboxylate; florpyrauxifen-benzyl , 1390661-72-9
  • Beflubutamid, 113614-08-7
  • Allyl 2,3-epoxypropyl ether, 106-92-3
  • 2-tert-butyl-4-methoxyphenol; tert-butyl-4-methoxyphenol
  • 2-[(1R,6R)-3-methyl-6-prop-1-en-2-ylcyclohex-2-en-1-yl]-5-pentylbenzene-1,3-diol, 13956-29-,
  • 2-(dimethylamino)-2-[(4-methylphenyl)methyl]-1-[4-(morpholin-4-yl)phenyl]butan-1-one, 119344-86-4
  • 1,1,3,3-tetramethylbutyl peroxyneodecanoate, 51240-95-0
  • (tert-butoxymethyl)oxirane, 7665-72-7
  • (3E)-dec-3-en-2-one, 18402-84-1

7th April

  • Sulcotrione, 99105-77-8
  • Ethylene bis[3,3-bis(3-tert-butyl-4-hydroxyphenyl)butyrate], 32509-66-3
  • DPX-Q8U80, 1254304-22-7
  • dichloromethane; methylene chloride, 75-09-2
  • Decan-1-ol, 112-30-1
  • Acetophenone, 98-86-2
  • 3,4-dimethyl-1H-pyrazole, 2820-37-3
  • 2-ethylhexyl (2E)-3-(4-methoxyphenyl)acrylate, 83834-59-7
  • 2-(2H-benzotriazol-2-yl)-p-cresol, 2440-22-4
  • 2,2-dimethyl-3-(morpholin-4-yl)propanal, 23588-51-4
  • 1H-Pyrazole, 3,4-dimethyl-, phosphate (1:1), 202842-98-6

1st April

  • Sodium bromate, 7789-38-0
  • reaction products of ammonium bromide and sodium hypochlorite, generated in-situ (no CAS no)
  • Potassium bromate, 02/01/7758
  • 5-methylhexan-2-one, 110-12-3

Just trying to keep on top of these proposals is enough to make my head spin!

And agreement on the HCs in 23rd ATP to CLP, but not published at time of writing

Many thanks to Dr. Parvinder Kaur, ERT (UK) , who spotted that the 23rd ATP was approved on 2nd April. We are currently waiting for formal publication in the Official Journal of the European Union (who knows? – it could be today!), but in the meantime these are the 2 draft documents awaiting publication:

0C88340B-E3B3-4450-BED7-05C0F214678E.pdf

4AA1F661-BF10-4B26-BE58-A2B986EB79A6.pdf

As far as we can tell, there is no obvious reason for the delay in publication, as all of the preliminary steps have been achieved:

  • It was notified to the WTO in September (25/9/2024), notification number: G/TBT/N/EU/1086.
  • The WTO has 60 days for comments, successfully carried out
  • The translations didn’t come through until the end of January, but they are available.

Ali writes again: “I’m thinking the delay after that might be the Nitrous Oxide. There was a parliamentary question about whether there were suitable alternatives for the hospitality/culinary industries, which triggered an Analysis of Alternatives report. EFSA have also asked for a review“.

However, we are not sure about why this is in limbo, and if you do have any information please let me know.

Regulations affecting Peanut Butter

Phil Rowley has spotted that Peanut Butter is being proposed for an EU Harmonised Classification! Before we get too excited, the reason for this is because it is an attractant for pests under the Biocidal Product Regulation. This makes it “an active substance under BPR”, and presumably therefore eligible for a Harmonised Classification.

As you probably know, peanut allergy is quite common, and potentially fatal (anaphylaxis), so we might have expected H317 or even H334 as a hazard classification (good luck with inhaling peanut butter!). However, the proposed HC is “not hazardous”.

Mark Reid of ChemReach Regulatory Consultancy has a detailed explanation of why this proposal has come about, and also the BPR definition of immunotoxicity under this LinkedIN post here: https://www.linkedin.com/posts/andrewpaulturley_if-youve-seen-that-austria-has-notified-activity-7315677975297880065-2Qi0. As you might imagine, this is a complicated situation.

Adam Batting also writes: Following on from the proposed CLH Peanut Butter entry, I am sure you already know this one but Peanut Butter is one of those topics that crops up all over the place.

Nearly 2 years ago, the TSA (Transport Security Association) in the USA was challenged over the physical status of Peanut Butter as whether it was a liquid or a solid.

They regard it as a liquid. Their logic being it conforms to the receptacle in which it is poured.

https://www.tsa.gov/travel/security-screening/whatcanibring/items/peanut-butter

So, as you mention, good luck inhaling peanut butter, but also don’t forget to check your carry on luggage for more than 100ml prohibited nut spreads!!

Many thanks again to Adam – truly, you couldn’t make this up.

Countdown to ChemUK 2025

We’re getting closer to CHEMUKEXPO 2025 on 21st and 22nd May at the NEC. I will be helping out on the Chemical Regulations Self Help Group on Stand E139, and looking forward to seeing many friends at the event.

The Chemical Regulations Self Help Group will also be running an open discussion on hot regulatory topics on Thursday 22 May 10.30 to 11.15, Stage 1 where we’ll discuss regulations currently concerning the industry and some practical solutions in our usual way (no such thing as a silly question!). If you are attending, it would be great to see you.

I’m delighted to see that Ali Potts (formerly of TT Environmental, now at WSP) is giving a talk on “Compliance Headaches! Products with Preservatives“. Wednesday 21st May (Day 1), Stage 3, 11:15 – 11:30, see https://www.chemicalukexpo.com/speakers/ms-alison-potts/

Another of the talks I’m looking forward to is Martyn Shenton of Blue Frog Scientific on PFAS https://www.linkedin.com/posts/blue-frog-scientific_chemuk-chemuk25-pfas-activity-7320462757743448065-zDVC

And there’s Chris Hughes of Embark Chemical Consulting on the new PMT/vPvM EU-CLP hazard classes, Thursday 22nd May, 11.45 to 12.00, Stage 5, see https://www.chemicalukexpo.com/speakers/christopher-hughes/ (where you can also sign up for your free ticket)

Infographic of the Month

Soap vs bodywash: https://www.linkedin.com/posts/mark-hilliard-4b4b9830_chemical-water-science-activity-7313455314584936448-JDDD

The Weekend Read

A great read from James Pomeroy on language and safety: https://www.linkedin.com/posts/globalhsemanager_processsafety-riskmanagement-safetyengineering-ugcPost-7311659255068020736-KzBr?

The Weekend Recipe

I thought you might like a recipe to use up any leftover mini eggs (Cadburys are the original, but other types exist). And before you ask “is there even such a thing as left over mini eggs?”, the answer is “sometimes, if you’ve hidden them”, or you may need to pick up a fresh bag or two to make this.

There were a few recipes floating around on social media, but I went “back to basics” and adapted a Mary Berry tiffin recipe.

Mini eggs fridge cake

  • 100g (3 1/2 oz) butter
  • 2 tablespoons golden syrup
  • 2 tablespoons cocoa powder
  • 200g (7 oz) broken digestive biscuits (can be uncoated or chocolate coated)
  • approximately 100 g broken/ crushed mini eggs
  • 200g (7 oz) milk chocolate to top the cake (I used an Easter egg for this)
  • more mini eggs to decorate

Method: line an 8 x 8 inch (20 cm square) tin with clingfilm, baking paper or greased foil (use a non flavoured oil like sunflower oil). In a large pan, melt the butter and golden syrup together over a low heat. When the butter is melted, take off the heat and stir in the cocoa powder to make a smooth mixture (try and get any cocoa lumps out at this stage). Then add in the broken digestive biscuits and mini eggs, and stir well until fully coated with the chocolate mixture, then press into the tin firmly and smooth out the surface with the back of a large spoon.

Freeze for 15 minutes to firm up (or leave in the fridge for an hour). Remove from the freezer or fridge, and ,elt the chocolate over a low heat (or over a double boiler, or in the microwave), and pour over the firmed-up cake, spreading out to make an even layer. Then decorate with the mini eggs, and put in the fridge to firm up. (As usual, if you score the setting chocolate into portions, it will make breaking it up into portions later on a bit easier).

As this recipe makes quite a dark chocolate taste, you could substitute the cocoa powder for drinking chocolate powder to make more of a “milk chocolate flavour” (and using Cadbury’s drinking chocolate should in theory make a very consistent flavour if you’re using their mini eggs). Of course, you can always use two types of chocolate for the topping, and swirl them together to make it more decorative.

“Free from” notes – to make this recipe if you have lactose intolerance, you’d have to use dairy-free mini eggs, margarine in place of butter, and a suitable milk-free biscuit (which could also be gluten free). Don’t forget to use a dairy-free cocoa powder too (there is a 2024 “safe list” here, but check all ingredients very carefully https://lucysfriendlyfoods.com/2024/02/21/dairy-and-nut-free-cocoa-powder-found-at-last/). You should probably use a bit less margarine than butter, as it tends to be “wetter” and you want the fridge cake to be quite firm when removed from the fridge (even if you store it in there).

Reasons to be Cheerful

Most of our April Reasons to be Cheerful continued our “Wonders of Chemistry” series:

For the 25th April newsletter, I was originally going to post a jokey video, but felt it was inappropriate in the light of Pope Francis’s passing. Instead here is an excellent recording of The Dream of Gerontius by Edward Elgar: https://www.youtube.com/watch?v=6IWivgS1cwU . (This is based on the poem of the same name by Cardinal Newman, https://newmanreader.org/works/verses/gerontius.html) .

Many thanks for reading this LinkedIn newsletter, and many thanks to everyone who has contributed, through sending in links, queries, comments etc. If you have anything you’d like to share, please email me or send a DM, and I’ll do my best to include it in the next Chemicals Coffee Time Monthly.

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Look forward to chatting to you in late May or early June.

Kind regards,

Janet

Janet Greenwood, TT Environmental Ltd

PS We’re happy for you to use this content in your own social media or newsletters, as long as you credit Chemicals Coffee Time. Please note that this newsletter highlights issues which may be of interest to your business, but is not intended as specific advice. We always recommend that you should do your own research. If you need consultancy help, please book a Quick Consultancy Call here: (https://chemicalscoffeetime.co.uk/quick-consultancy-calls/), or Quick Consultancy Email here: https://chemicalscoffeetime.co.uk/quick-consultancy-emails/

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