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Chemicals Coffee Time Monthly, May 2025

Posted
Updated
ByEmma

Dear Reader,

Well, May was quite a month! The current UK government looking for closer ties with the EU, the EU Classification and Labelling Inventory being copied into the ECHA Chem website, a new Pope, and much more.

A highlight for me was volunteering on the Chemical Regulations Self Help Group stand at ChemUK 2025, alongside Peter Godfrey and Patricia Wormald of Cambridge Environmental Assessments, part of RSK ADAS Ltd. Thank you so much to Ian Stone , Jini Stone and all of the organisers for a superb event. We had a wonderful time meeting old friends and making new ones, and I’m already looking forward to ChemUK 2026!

Hearing from the HSE, DEFRA and the UK

Starmer plans to rejoin the EU?

The news of the EU/UK summit which took place on Monday was interesting. Ironically, the best summary of the agreements I could find was actually from the Council of Europe, see https://www.consilium.europa.eu/en/meetings/international-summit/2025/05/19/

This is quite a confusing document, as although it starts by saying “In order to strengthen the bilateral relationship, the UK and the European Commission reaffirmed their commitment to the full, timely and faithful implementation of the withdrawal agreement, including the Windsor Framework, and the trade and cooperation agreement.“, the actions later on do not appear to be much to do with withdrawal.

For example, the fishing rights of EU boats in UK waters, which were due to be removed next year have now been extended until 2038. There also seems to be a lot of talk about “closer co-operation”.

Under the heading “Strengthening economies while protecting the planet and its resources”, there are several points where the chemical industry might be affected (my comments in brackets)

The UK and the European Commission should work towards:

  • the UK’s possible participation in the EU’s internal electricity market (potentially lowering energy prices)
  • a common sanitary and phytosanitary area
  • linking both emission trading systems (ETS) (this could be quite important for large manufacturers within ETS but it’s not clear if this will be a positive or negative step)
  • better implementation of the rules for entry and temporary stay of natural persons for business purposes, and the recognition of professional qualifications, set out in the existing trade and cooperation agreement (helping business travel)

There is no mention of chemicals per se in the EC document, although one of the people I met at ChemUK thinks that chemicals may have been mentioned in the same breadth as food.

The Daily Telegraph notes this on the food agreement: “In return for granting access to British waters for much longer than was expected, the UK has secured a veterinary agreement to boost trade.

The Swiss style-deal that removes border checks and red tape on agri-food will be permanent.

But it does mean Britain has agreed to align with EU plant and animal health laws and will therefore be subject to European Court of Justice decisions over them.”

Handing back jurisdiction of some laws inside the UK to the ECJ also does not sound like withdrawal to me!

If you want to hear the official line, the joint EU/UK press release is available here: https://assets.publishing.service.gov.uk/media/682afb528999f671f3c243d6/UK_EU_Summit_-_Joint_Statement.pdf .

This is very much a “watch this space” moment.

HSE opinions on Mandatory Classifications in the UK

The HSE have published two batches of opinions in a single document, which you can download as an .xls file from here: https://www.hse.gov.uk/chemical-classification/classification/publication-template.htm .

These opinions need to be signed off by the Secretary of State, and notified to the WTO, but I don’t know if any have been stopped during this late stage.

The first set are HSE opinions on MCL proposals already existing or agreed in Europe (which will not go through a GB consultation process)

  • Trihydrogen pentapotassium di(peroxomonosulfate) di(sulfate), 70693-62-8
  • Piperonal; 1,3-benzodioxole-5-carbaldehyde, 120-57-0
  • N-1,3-dimethylbutyl-N’-phenyl-p-phenylenediamine, 793-24-8
  • Thymol; 5-methyl-2-(propan-2-yl)phenol, 89-83-8
  • Bronopol; 2-bromo-2-nitropropane-1,3-diol, 52-51-7
  • 4,4′-methylenediphenol; bisphenol F, 620-92-8

However the second set are even more interesting, as they are HSE opinions on GB-only MCL entries, highlighted as “Article 37A proposals” in column F, which means that these have gone through public consultation in the UK (and they also mean more divergence from the EU Harmonised Classification List):

  • N-carboxymethyliminobis (ethylenenitrilo)tetra(acetic acid) (DTPA) and its pentasodium and pentapotassium salts, 67-43-6; 7216-95-7; 140-01-2
  • ethylene glycol; monobutyl ether (EGBE), 111-76-2
  • Silanamine, 1,1,1-trimethyl-N-(trimethylsilyl)-, hydrolysis products with silica, 68909-20-6

The consultation reports are linked from the spreadsheet as well.

DEFRA’s session at ChemUK

We were waiting to see what DEFRA would say about UK-REACH, but I ended up missing this session. Luckily Andrew Bourne, who has just set up his own business, Bourne Chemical Compliance Ltd (having worked at several big-name consultancies), went to this session and has a report here: https://www.linkedin.com/pulse/uk-reach-same-system-different-bourne-chemical-compliance-uxove/ .

Many thanks to Andrew for sharing this summary with us.

Reading between the lines of what was actually said, it looks like the UK-REACH registration deadlines may be extended further – which is hardly surprising given the political changes in the relationship between the UK and EU. As I said to several people at ChemUK, regulations are downstream of policy; and policy is downstream of politics.

Keeping an Eye on ECHA and the EU

Breaking news – EU to adopt GHS Rev 10

The EU are working towards moving EU-CLP towards adopting GHS revisions 8,9 and 10, see Amy Moram of WSP’s post here; https://www.linkedin.com/posts/amy-fearon-934342b0_clp-ghs-regulatoryupdate-activity-7333778606491398145-0eRi . Amy says this will be another Delegated Act, which means no public consultation, and it’s expected to be published by the end of 2025, presumably with the usual 2 years plus implementation timescale.

The link to the main document is here: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14687-Commission-Regulation-adapting-CLP-to-technical-progress-alignment-with-GHS-revisions-8-to-10_en (link courtesy of Ali Potts of WSP).

Of course, this doesn’t mean that every part of these GHS revisions will be adopted in the EU, a real “watch this space” moment; and we don’t know what will happen with GB-CLP yet (but do contact me if you have any information!).

A flurry of EU CLH proposals

I seem to be putting these new EU Harmonised Classification Proposals into our weekly email newsletter nearly every week! You can find them all via this link: https://echa.europa.eu/registry-of-clh-intentions-until-outcome/-/dislist/details/0b0236e18a13d769 .

Important point for UK businesses – if you’re in the UK, don’t forget to comment on any of these EU CLH proposals which affect your business! This is because if they are adopted under GB-CLP, the current protocol does not include a UK consultation as the EU one is deemed to be sufficient.

  • styrenated phenol, CAS no , which is being proposed for Aquatic Acute 1 H400, and Aquatic Chronic 1 H410
  • 2,4,6-tris(dimethylaminomethyl)phenol* (EC 202-013-9, CAS 90-72-2); and
  • 1H-benzotriazole [1] and its inorganic salts, with the exception of those specified elsewhere in this Annex (EC 202-394-1 [1], CAS 95-14-7 [1])

And another HC proposal – change to TFA

Steven Brennan of Foresight brings us news of yet another Harmonised Classification proposal, this time its for Trifluoroacetic Acid, TFA. Steven has a very good summary of the changes here: https://www.linkedin.com/posts/dr-steven-brennan_harmonised-classification-and-labelling-consultations-activity-7332697260452888578-BLug, and you can find the full details at ECHA: https://echa.europa.eu/harmonised-classification-and-labelling-consultation/-/substance-rev/80001/term.

(You can sign up for Steven’s excellent free newsletter here: https://www.useforesight.io/newsletter, its certainly something which I find very useful, although his software covers far more regulations than we cover in this newsletter. Together with his business partner, he seems to have got the balance of AI/ human input just right).

EU introduces another business type – small to mid capitalisation

Steven also has this news: “The EU just introduced a new company category—small mid-caps—designed to ease the pain of growing companies. With up to €400M in annual savings on the table, could this reshape compliance for firms caught between SME perks and big-business obligations?” More on this at https://www.useforesight.io/news/eu-introduces-small-mid-caps-to-cut-compliance-burdens-across-industrial-sectors

I wonder if this will change the SME definitions used in EU-REACH registrations to give discounts? (and checked by ECHA to make sure they’re charging companies the right amount!)?

The “original” EU SME definitions are here: https://single-market-economy.ec.europa.eu/smes/sme-fundamentals/sme-definition_en (and there’s also a handy online self-assessment tool if you’re not sure what your company size is). As far as I’m aware, the UK still use these definitions as well.

EU C&L on ECHAChem

Here at TT Environmental, we have been concerned about the migration of the EU’s Classification and Labelling Inventory from the main website to ECHA Chem, given the enormous problems with REACH registration dossier migration (currently still 300 dossiers needing to be updated, but we don’t know which substances are affected!).

This migration process started in May 2025, and after ECHA’s 15-minute webinar about the “new C&L” recently, several things have become clear:

  • this is just the first phase of the move across to the ECHAChem website, and not all of the functionality is in place yet (e.g. identities of notifiers)
  • it will take some time for all of the data to be in place
  • navigation is very complicated
  • people miss the one-page table of the “old CLI”, and it’s not clear how there is any improvement for the end user (see the questions for the webinar)

On the plus side, some of the dodgier entries, e.g. water classified as flammable (probably carried out as a trial of the system), do seem to have been cleansed.

Personally, I do not see why ECHA couldn’t have cleansed the existing database and added in who the notifiers are with a lot less time and expense. I haven’t found anything so far which actually helps in either finding or understanding C&L inventory entries any better than the existing system, and it seems to be a lot harder to get hold of data. Maybe ECHAChem will be easier for ECHA to upload data to, but they don’t seem to be thinking about user experience at all.

And it’s worrying that there doesn’t seem to be a way to access either the new C&L or the new REACH dossiers on ECHA Chem per se, like there is at ECHA where you can get to the old C&L here: https://echa.europa.eu/information-on-chemicals/cl-inventory-database and the old REACH registered substance list here: https://echa.europa.eu/information-on-chemicals/registered-substances .

When you think about the fact that there is also no tabular layout for the C&L entries for an individual substance, it starts to look like ECHA is not going to display information in tables on ECHAChem, which to a nerd like me seems like a bad thing, as it stops us looking for patterns.

Interesting times!

New IUCLID format

Another day, another change to the ECHA systems – this time it’s an update to IUCLID, see https://echa.europa.eu/-/new-iuclid-release-available . There was also a webinar on Wednesday about the changes, which you can find here: (link here).

If you use IUCLID online, then the system will update automatically, but if you have a hosted version you will need to upgrade it (that is if you are using the EU version of IUCLID.

However, I understand from friends who are using IUCLID for UK-REACH that the HSE’s systems use an older version! I can’t find anything online about which IUCLID version is currently in use in the UK, but am happy to hear from anyone who knows the current state of play and share it with everyone.

POPs update (EU only)

ECHA write “The European Commission has adopted two amendments to the Annex I to the Persistent Organic Pollutants (POPs) Regulation on 5 May 2025:

  • Adding UV-328 to Annex I with specific exemptions; and
  • Extending the expiry date of the specific exemption for the use for fire-fighting foams (already installed in systems) containing PFOA, its salts and PFOA related substances. Setting new concentration limits for PFOA related compounds in fire-fighting foam.”

Shweta Goyal also spotted some earlier amendments which I missed, writing on LinkedIn:

“On April 14, 2025, the European Commission adopted a delegated regulation amending the EU Persistent Organic Pollutants (POPs) Regulation (EU) 2019/1021. This amendment introduces: • Updated substance identification for PFOS (Perfluorooctane sulfonic acid and its derivatives) • Stricter concentration limits for PFOS as an unintentional trace contaminant (UTC) The new UTC limits will take effect on December 3, 2025”.

The POPS divergence continues…

Where on earth is the 23rd ATP to CLP?

Regulatory nerds like me may remember that one of our LinkedIn friends sent through the two parts of the 23rd ATP to CLP which were approved on the 2nd April (as published in Chemicals Coffee Time 11th April 2025, https://chemicalscoffeetime.co.uk/archive-2/chemicals-coffee-time-11th-april-2025/).

However, it seems that it is still being scrutinised (hat tip Kathryn Tearle of British Coatings Federation ), and it may be several months before it is finally published.

Around the World

Switerland’s ChemO updated

As you’re probably aware, Switzerland follows EU chemical legislation very closely, and usually updates their own rules quickly following EU changes. Amy Fearon of WSP summarises this nicely here: https://www.linkedin.com/posts/amy-fearon-934342b0_chemicalcompliance-regulations-switzerland-activity-7321184217923543040-EsAQ

Minnesota PFAS fees

If you make articles containing PFAS and export them to the USA, you may be aware that Minnesota has just introduced fees for PFAS. Miguel Gascón of Commscope has very kindly sent through the link to this decision, see https://www.pca.state.mn.us/get-engaged/pfas-in-products-reporting-and-fees.

He has also clarified that the $1,000 fee will be per company (rather than per SKU, as originally feared), see this guidance document: c-pfas-rule1-07.pdf

Chemical snippets

Process Safety Corner

Recent incidents:

Infographic of the Month

A timely infographic from Andy Brunning of Compound Interest on the chemistry of the Papal Conclave smokes and how they produce the two colours: https://www.compoundchem.com/2025/05/08/pope-smoke/

The Weekend Watch/ Read

A very thought-provoking post from Steve Abbot on Green Chemistry and how it doesn’t seem to have achieved much in 25 years (with data for us nerds!) https://www.linkedin.com/posts/profstevenabbott_the-outcomes-of-25-years-of-green-chemistry-activity-7327612078867771392-Ytx5/ .

The Weekend Recipe

When I was in Scotland (visiting my Mother in her Care Home) on the weekend before Easter, Mike got fed up with some rather plain commercially made oat biscuits (could it be H*bn*bs?), and decided to make some ginger oaty biscuits based on a plain recipe called “crunchy oat cookies”.

Unfortunately, he had a couple of problems. Firstly the cookies didn’t flatten out in the oven (probably because he used butter instead of the margarine specified in the recipe); and secondly because he thought they weren’t done enough and increased the cooking time, which made them rather harder than they should have been. So I remade his recipe with a couple of tweaks, and it worked a lot better.

Ingredients

  • 3 oz (75g) porridge oats (not whole oats – if using these, blitz briefly in a blender so there’s a bit of oat flour present too)
  • 1 teaspoon ground ginger (we use Schwarz, supermarket brands tend to be less fiery)
  • 2 oz (50g) plain flour
  • 2 oz (50g) soft butter (eg Lurpak spreadable) or margarine (do NOT use ordinary butter)
  • 2 oz (50g) granulated sugar
  • 1 oz (25g) / 1 level tablespoon golden syrup
  • 1/2 level teaspoon bicarbonate of soda

Method

Put your oven on to gas Mark 4 to preheat, and grease one large or two medium baking trays. Whisk the porridge oats, flour and ground ginger together in a bowl. In a large pan, melt the soft butter or margarine with the sugar and golden syrup. When fully melted, stir in the bicarbonate of soda, and then stir in the flour/oat/ ginger combination and mix together well. Make 14 walnut sized balls by hand, flatten them a bit, and place on the tray (leave plenty of space). Bake for between 11 and 15 minutes until just done, then cool on the baking tray for a few minutes. Slide off onto your cooling rack and cool completely.

Findings – this second batch worked perfectly well and it’s a lovely ginger flavour. I am so proud of Mike’s recipe, well done that man! Top tip – if you are feeding a crowd, or have teenagers in the house, just double the quantities for a larger batch.

Reasons to be Cheerful

For May, we’re in a Hale and Pace season:

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.

It would be great if you’d like to subscribe to this newsletter on LinkedIn if you haven’t already, and if you want to get the news early, and much, much more (because we can’t include everything in this monthly round-up), you can sign up to our weekly email newsletter here: https://chemicalscoffeetime.co.uk/. (This website includes the email archive, with both open-access and subscriber-only content).

Chemicals Coffee Time Monthly and Weekly have grown over time to support the chemical industry, and are free to read and free from adverts. If you’d like to support our work, why not treat yourself to one of our new Chemicals Coffee Time mugs? https://chemicalscoffeetime.co.uk/product-range-mug/ .

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

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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