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Chemicals Coffee Time Monthly, December 2025

Posted
Updated
ByEmma

Dear Reader,

I hope you’ve had a lovely Christmas. We’ll start with the December news, then look back at the year briefly, and forward to 2026.

Hearing from the HSE, DEFRA and the UK

UK REACH registration deadlines decided

The UK Government’s response to the UK-REACH deadlines consultation were published on the Monday before Christmas, and although industry prefers Option 2 (which maintains 2 years between each deadline), the Government is going with Option 1 (delaying the deadline but with one year between tonnage bands).

“Subject to the consent of Scottish and Welsh Ministers, the UK government will be legislating to extend the current deadlines to 27 October 2029, 27 October 2030 and 27 October 2031. “

The consultation did acknowledge the elephant in the room, which is that until industry knows what the ATRm will look like, nobody can prepare for it – but that was as far as it went.

https://www.gov.uk/government/consultations/uk-reach-extending-dossier-submission-deadlines-for-transitional-registrations/outcome/summary-of-responses-and-government-response

Good to see the CIA, in their response, asking for a Swiss-style recognition to avoid bureaucracy https://www.cia.org.uk/cia-news/key-chemical-regulation-adding-bureaucracy-with-no-safety-or-environmental-benefits/1443.article

DUINs – past their sell-by date?

There has been some concern about the fact that the DUIN window is quite some time ago, and the inability of GB businesses to bring or make new substances under REACH without incurring significant cost is starting to impact innovation, particularly for SMEs.

BASA (the British Adhesives and Sealant Association) have produced an excellent article on this here: https://members.basa.uk.com/news/Details/from-innovation-to-inaction-the-duin-drag-on-uk-business-298248.

They have suggested that a DUIN extension might be helpful: “BASA fully supports the extension of the DUIN process to include substances that had not been previously imported but do have an existing EU REACH registration.” If this issue is impacting your business, it might be an idea to lobby through your trade organisation.

Environmental Improvement Plan published

DEFRA published the 2025 Environment Improvement Plan on the 1st December (hat tip Alison Potts of WSP): https://assets.publishing.service.gov.uk/media/692d8d9cce50d215cae962a5/Environmental_Improvement_Plan__EIP__2025.pdf .

What’s that got to do with chemicals, I hear you ask? Well, commitment 40 is worth a read:

Commitment 40: Reform UK Registration, Evaluation, Authorisation, and Restriction of Chemicals (REACH) to enable protections that address chemical pollution to be applied more quickly, efficiently and in a way that is more aligned with our closest trading partners, especially the EU, by December 2028.

One of the actions below Commitment 40 was interesting, too:

  • Take regulatory decisions made by other trusted jurisdictions as the starting point for UK regulatory decisions to enable new protections to be applied more quickly and more efficiently, and to align regulation more closely with our closest trading partners unless there are compelling reasons to diverge….

Wow! Could we really end up with a Swiss style arrangement?

Environmental modelling under UK-REACH

Steven Brennan of Foresight has spotted something interesting. He writes:

“… the Environment Agency has published its assessment of GB specific changes to EUSES, the exposure model used under REACH. This is technical, but the implications are clear. GB will continue to use EUSES, but with UK specific parameters for river dilution, sewage treatment, rainfall, windspeed and soils. These changes generally produce higher predicted environmental concentrations than the EU defaults.”

The full article is here: https://www.linkedin.com/posts/dr-steven-brennan_chief-scientists-group-report-summary-ugcPost-7407064918660632577-6Cv6.

Many thanks to Steven for his excellent service, via his free newsletter https://www.useforesight.io/newsletter and commercial tracking service https://www.useforesight.io/.

Keeping an Eye on ECHA and the EU

“Stop the clock” published on 3rd December

The EU’s”stop the clock” regulation was published on 3rd December 2025 in the Official Journal:

That means that it came into immediate legal effect on the 23rd December 2025. Thanks to Caroline Raine for letting us all know so promptly.

However, as Kathryn Tearle of British Coatings Federation reminded us via the Chemical Hazards Communication Society – (CHCS) forum, the “stop the clock” deadline extensions only apply to specific obligations (see below), and not to the dates for the new hazard classes or to other dates for transitional arrangements in the 2024 amendment which are not being simplified.

Affected by the new 1st January 2028 implementation dates:

  • Formatting rules and minimum font size requirements for labels
  • Relabelling duties triggered by self-classification changes
  • Advertising requirements linked to CLP classifications
  • Information obligations for distance selling
  • Label requirements at filling stations

Not affected – everything else, including dates for compliance with the new hazard classes; or the final date in the 22nd and 23rd ATPs.

Ivo Erens also comments via the CHCS forum: “The new rules for fold-out labels are not part of the Stop-the-clock. Thus as of July 1st 2026 fold-out labels should comply with the new rules as set-out in the November 2024 CLP revision (Regulation (EU) No. 2024/2865).”

As usual, if you are involved in CLP/ SDSs, we recommend you sign up to the CHCS discussion forum, which you can do here: https://chcs.org.uk/chemical-hazards-forum

One Substance One Assessment published

Caroline Raine also writes : Another one for the newsletter… “Please be informed that the “One Substance, One Assessment” package has been published in the EU official journal.

  • Regulation establishing a common data platform on chemicals
  • Regulation on reattribution of scientific and technical tasks and improved cooperation among Union agencies
  • Directive on the reattribution of scientific and technical tasks to ECHA”

EUDR deadline delay – progress

The EU parliament had a vote this week which agreed with the Commission’s proposals to extend the EUDR deadlines, and other amendments. (Of course, this still needs to go through the publication process in the Official Journal, but the in-principle decisions have been made).

There is a very good article explaining the details of this here: https://www.linkedin.com/posts/gts-global-traceability-solutions_eudr-parliament-final-vote-activity-7407037153454497794-sX8-/ .

Chemical data transition to ECHA Chem

The ECHA website had a glitch on the chemical search just before Christmas, which only showed a link to ECHA Chem. This was quite confusing, as ECHA Chem is on “pause” until the 5th January 2026 for some updates, so the most up to date information is still (mainly) on the main ECHA website.

Luckily by the afternoon the chemical search had reappeared on the main website, but it’s a reminder that this will soon be going. The full set of deadlines is here: https://echa.europa.eu/echa-chem, and shows the REACH dossiers and Brief Profile as “Decommissioned on 18 December 2025”. So the situation is a bit messy, and ECHA are clearly trying to push us to use ECHA Chem soon.

We also know that other chemical information, such as the Candidate List (SVHC list) is not up to date at ECHA Chem, but it is “live” on the main ECHA website.

This may turn out to be a(nother) difficult transition for the ECHA IT team.

Chemical snippets

Process safety corner

And a very good insight from Chris Brookes-Mann of the Health and Safety Executive about learning from things going well, as well as when they go wrong, in a couple of comments on this post: https://www.linkedin.com/posts/georginapoole_is-this-the-safety-revolution-that-nobody-activity-7404364696621162496-0yei. He writes:

“It does bring me neatly to your point about leaders asking for evidence, though, to which I would always point out that learning from what goes well as well as what goes wrong does happen in many organisations; it’s just overseen by Operations Departments rather than Safety Teams, and is known as Industry Good Practice. For instance Dr Conklin, to his great credit, makes clear his Five Principles of Human Performance are basically borrowed from the Institute of Nuclear Power Operators. Then you’ve got things like control room design and alarm management (the Engineering Equipment and Materials Users Association), crew resource management (the International Civil Aviation Organization), and so on.

Sure, safety teams will have had a hand in all of the above – and much, much more – but often it’s not so much the case that the idea of learning from normal work is completely alien to senior leaders, but the way it’s framed by safety people.“

Looking back on 2025

Despite dealing with a lot of regulatory uncertainty (UK-REACH deadlines, EU CLP label formats etc) there were quite a few highlights in 2025 including

And, in a couple of personal highlights, I was deeply honoured to receive Honorary Life Membership of the Society of Dyers and Colourists in November, and to return the favour in December by conferring Honorary Life Membership of the Chemical Regulations Self Help Group on the current SDC president, Stuart Wilkinson.

And looking forward to 2026

There is a lot of regulatory uncertainty in both GB and the EU (quite apart from commercial uncertainty):

ChemUK 2026 news

On a happier note, ChemUK 2026, on the 21st & 22nd May next year in Hall 5 at the NEC is shaping up to be another excellent expo.

The Chemical Regulations Self Help Group will be on Stand H160, and we are discussing the day/time for our public meeting with Ian Stone and his team, details to be published once they have been decided.

Infographic of the Month

It has to be a Science of Christmas infographic https://www.labroots.com/trending/chemistry-and-physics/16405/science-christm

The Weekend Watch/ Read

And I thought you’d like – Santa fails his “elf and safety” check https://www.facebook.com/reel/1443946780775728

The Weekend Recipe

As our weekly email readers may have picked up, I’m adjusting to life as someone with lactose intolerance. So I thought I’d try one of our seasonal favourites with Arla’s lactose free cream, which contains lactase to remove the lactose, and is thickened with carrageen (a seaweed), just to make sure it works correctly. (It’s a tough job, but someone’s got to do it!)

Pheasant, apples whisky and (lactose-free) cream (for 2 people)

  • 2 pheasant breasts, cut into strips or chunks, according to your preference
  • a couple of tablespoons of finely chopped red onion
  • 2 medium or 1 large Cox’s orange pippin apple, in slices or chunks (again, according to taste)
  • whisky – a good glug
  • Arla lactose free cream
  • butter and oil for frying

Method: heat your frying pan, and add the oil then the butter. Fry the onion gently for about 5 minutes, then add the strips or chunks of pheasant to brown them, then reduce the heat and fry for around 5 to 10 minutes until cooked through (timing will depend on how thick the pheasant pieces are – check the fattest one). then add the apples and brown them. Pour in a good glug of whisky, and bubble to remove some of the alcohol, then add a good amount of lactose free or double cream, salt, and a couple of grindings of freshly ground black pepper. Bubble the sauce for a couple of minutes until it is thickened to your liking. Serve with basmati rice to soak up the sauce.

Findings: the Arla lactose free cream worked really well, it is slightly sweeter than normal cream, so you may need to ensure your apples are quite tart, or use a little more whisky, to get a balanced flavour. This did work very well. You can substitute chicken for the pheasant, but it’s definitely more flavourful with pheasant.

Reasons to be Cheerful

We continued with Mitchell and Webb during December (although mainly their older sketches, as these tend to be funnier…)

I thought you might like some Christmas music, and one of my favourites is “I believe in Father Christmas”, Greg Lake, which “samples” the Troika section from Lieutenant Kije by Sergei Sergeyevich Prokofiev: https://www.youtube.com/watch?v=yfY4b1NszpY; and the full Lieutenant Kije suite, conducted by Andre Previn: https://www.youtube.com/watch?v=fr6eFP07uU0.

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).

Look forward to chatting to you in late January or early February.

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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