What topic are you interested in?

Subscribe | About | Help

< All Topics
Print

Chemicals Coffee Time Monthly, July 2025

Posted07/08/2025
Updated07/08/2025
ByEmma

Dear Reader,

I hope this finds you safe and well, and not adversely affected by the weather. Here in the UK, we seem to be varying between scorching sunshine and cool and rainy conditions, without having a “nice summers day” where it’s just the right temperature.

Breaking news – Titanium Dioxide ruling in the EU

Some breaking news at the start of August – the Titanium Dioxide appeal against the Carcinogenicity classification has been upheld!

See this press release https://curia.europa.eu/jcms/upload/docs/application/pdf/2025-08/cp250099en.pdf and the full judgement is here: https://curia.europa.eu/juris/document/document.jsf?text=&docid=302997&pageIndex=0&doclang=EN&mode=lst&dir=&occ=first&part=1&cid=9043257

Huge thanks to Darren Abrahams of Steptoe and everyone else involved in acting on behalf of industry, and also thanks to Aaron McLoughlin of FleishmanHillard for spotting the news.

It feels like a real victory for science over the legal arguments put forward against the appeal. It also means that the divergent hazard classifications for Titanium Dioxide and its mixtures between the EU and GB will disappear, as it will be non-hazardous in both jurisdictions.

We will need to see how ECHA respond to this news, and how quickly the Harmonised Classification list will be updated. Some interpretations are that as the classification has been annulled, it should be removed immediately. You may want to confirm what the Competent Authority in your jurisdiction wants you to do, though.

And well done to the HSE, who had already removed the carcinogenicity classification from the UK via the Mandatory Classification List some time ago.

Hearing from the HSE, DEFRA and the UK

Proposed extension to UK-REACH deadlines

There’s a DEFRA consultation on extending the UK REACH registration deadlines which has recently been published this morning, see https://consult.defra.gov.uk/reach-policy/extending-the-uk-reach-submission-deadlines/

The consultation itself has 3 proposals for extending the deadlines, and none for keeping them intact, so it looks like some kind of extension is definitely going to happen.

The proposed deadlines are:

  • Option 1: October 2029, October 2030, October 2031 (UK Government favoured option)
  • Option 2: April 2029, April 2031, April 2033
  • Option 3: April 2029, April 2030, April 2031

The consultation is open from until the 8th September, and can be answered by e.g. trade bodies, and also by individual companies and individual persons.

Many thanks to Steven Brennan of Foresight, his system for tracking policy and regulatory changes is definitely working! You can sign up for his newsletter here https://www.linkedin.com/newsletters/7165705027863429120/, or follow him on LinkedIn here: https://www.linkedin.com/in/dr-steven-brennan/ .

Oxybenzone limits in Cosmetics for GB

There is a reduction on oxybenzone limits in cosmetics, see https://www.linkedin.com/posts/dr-steven-brennan_the-cosmetic-products-restriction-of-chemical-activity-7353144147664334850-zbUT . The regulation itself is here: https://www.legislation.gov.uk/uksi/2025/901/made/data.pdf. Important news for anyone who uses high SPF sunscreens, as I understand that these need a combination of chemical and physical sunscreens to give that strength of protection.

Keeping an Eye on ECHA and the EU

ECHA proposals out for comments

The first one is yet another proposal for the Candidate (SVHC) list, for 1,1′-(ethane-1,2-diyl)bis[pentabromobenzene], CAS no 84852-53-9 to be added to the Candidate List, see https://www.echa.europa.eu/web/guest/substances-of-very-high-concern-identification/-/substance-rev/80138/term. This consultation closes on the 11th August.

We also have two proposals for Occupational Exposure Limits, as ECHA have been given responsibility for the EU-wide OELs. There are two substance OELs being debated:

  • Anthraquinone, CAS no 84-65-1
  • Oximes: Butanone oxime, Acetone oxime, CAS nos 96-29-7 and 127-06-0

You can comment here (closing date 16th August 2025 for both OEL consultations): https://echa.europa.eu/oels-pc-on-oel-recommendation (hat tip Heidi Rasikari of ECHA for highlighting these OEL changes).

There are also a whole pile of CLH proposals and alterations, which I listed in detail in our weekly Chemical Coffee Time newsletter emails and which you can find here: https://echa.europa.eu/registry-of-clh-intentions-until-outcome

EU simplification of chemical regulations published (including mandatory CLP label format changes being removed)

A reader writes: The MEPs have debated proposals with the European Commission on the latest chemicals proposals, see https://www.europarl.europa.eu/news/en/agenda/briefing/2025-07-07/15/chemicals-package-meps-to-debate-proposals-with-the-european-commission

Press release is at https://ec.europa.eu/commission/presscorner/detail/en/ip_25_1755 and FAQ at https://ec.europa.eu/commission/presscorner/detail/en/qanda_25_1759 , the action plan is https://single-market-economy.ec.europa.eu/publications/european-chemicals-industry-action-plan_en and proposal for simplification (an “omnibus”) here: https://single-market-economy.ec.europa.eu/publications/simplification-certain-requirements-and-procedures-chemical-products_en

Many thanks to our reader, who was first off the mark to spot this, and to everyone else who let me know too.

This is the announcement which ChemicalWatch suggested would remove the CLP label formatting changes. The details of the changes are contained within the “omnibus” proposals, with two main documents to look at.

Firstly, a regulation which delays the implementation of some CLP changes, but without going through the with a fine tooth comb, I’m not sure what this will involve (rather like the complex way the deadlines were brought in!), see https://single-market-economy.ec.europa.eu/document/download/e2297bd6-90cc-4d30-8d71-e5f8fb610221_en .

Secondly and more importantly, the big changes on simplification for CLP, Cosmetics and Fertilisers, which are held here: https://single-market-economy.ec.europa.eu/document/download/ebed9e83-9e40-4b0c-8439-2d3f2af190ae_en- , which alters some of the provisions brought in under the CLP Legislative Act, (see https://eur-lex.europa.eu/eli/reg/2024/2865/oj/eng)

One key change seems to be “in Article 31, paragraph 3 is replaced by the following: ‘3. The label elements referred to in Article 17(1) shall be clearly and indelibly marked. They shall stand out clearly from the background and they shall be of such a size and be spaced in such a way as to be easily read“

However, I’ve not had time to go through this in detail, and if this change affects you it’s important to do your own research – although I’m sure the trade bodies will be providing guidance and comments on this very soon.

Some of the other things I’ve noticed so far:

Steven Brennan has produced a “cheat sheet” on the proposals, which may be helpful: https://www.linkedin.com/posts/dr-steven-brennan_chemicals-industry-action-plan-ugcPost-7348363519144169473-381f

As usual with any important regulatory change from the EU, there will be a lot to unpick from this, and I would welcome your thoughts/ comments/ discussion to help our readers understand what the practical implications will be.

SCIP to go?

News that the EU may be rolling back on SCIP, which is the EU database for information on Substances of Concern In articles as such or in complex objects (Products) established under the Waste Framework Directive (WFD), https://echa.europa.eu/scip, f

Steven Brennan reports that it may be dropped, see https://www.linkedin.com/posts/dr-steven-brennan_scip-environmentalregulation-eucompliance-activity-7353684669164339200-uAhC .

However, rumour has it that if the Digital Product Passport is implemented, it would duplicate the SCIP information, so this may simply be a different way of reporting the same data, rather than a removal of a regulatory burden.

Talc proposed for a Harmonised Classification

Following on from the recent announcement from the IARC that they think talc is a Category 1B carcinogen by inhalation (see my initial doubts in a recent newsletter here: https://chemicalscoffeetime.co.uk/archive-2/chemicals-coffee-time-11th-july-2025/ ), the EU has now entered the fray. Many thanks to one of our anonymous readers for spotting this issue, we really appreciate it.

The CLH opinion on Talc classification was adopted on the 16th July, see https://echa.europa.eu/registry-of-clh-intentions-until-outcome/-/dislist/details/0b0236e186f6f6b2 .

The RAC opinion was published on the 9th July and can be found here: https://echa.europa.eu/documents/10162/03b74f7b-10ca-3e74-514b-e7f2b24c98ec

The story so far: the initial classification proposal from the Netherlands’ Competent Authority was for a harmonised classification of ‘talc not containing asbestos or asbestiform fibres’ with STOT RE 1; H372 (lungs, inhalation) and Carc. 2; H351.

This initial classification proposal included a new Note, which would have read “If the substance is to be placed on the market as fibres (with diameter < 3 μm, length > 5 μm and aspect ratio ≥ 3:1) or particles of the substance fulfilling the WHO fibre criteria or as particles with modified surface chemistry, their hazardous properties must be evaluated in accordance with Title II of this Regulation, to assess whether a higher category (Carc. 1B or 1A) and/or specification of routes of exposure should be applied“.

However, the RAC opinion is that Talc should automatically be classified Carc. 1B, H350, as well as STOT RE 1; H372 (lungs, inhalation). This is the opinion which has been adopted, and which must now go through the sign-off procedure, and the final decision by the European Commission has apparently been postponed until 2026.

I suppose we shouldn’t be surprised that the RAC are following IARC, but I have other doubts as to the evidence available to support this which I have not published yet, so may come back to this topic in a later newsletter or LinkedIn article.

The problem with a hazardous classification like this is that it will immediately impact on downstream users in the Food, Cosmetics, Pharmaceutical and Packaging sectors, as Giusy Chiricosta has noted here: https://www.linkedin.com/posts/giusy-chiricosta-779b6431_eu-activity-7349189442194046976-BFZo.

Ethanol CLH submission date pushed back

Speaking of Harmonised Classification proposals with a broad impact, the ethanol classification submission date has been pushed back to 31 December 2026, which was published in the formal “intention” listed above, hat tip Aaron McLoughlin again: https://www.linkedin.com/posts/aaron-mcloughlin-1a86281_registry-of-clh-intentions-until-outcome-activity-7347585445809012736-s4xJ

EU Reopens Glyphosate Review-

ECHA write – “The EU has asked ECHA to reassess glyphosate’s carcinogenicity after new findings from the Ramazzini Institute. A reclassification could reshape REACH obligations and force changes to labelling, safety, and market access. Read the full article“

(and see below for Ashley Quigley’s take on the Ramazzini Institute’s paper…)

Around the World

GHS Rev. 11, 2025 published

The publication of GHS Rev. 11, 2025, has just been announced, thanks to Tatiana Moneró of Lisam for highlighting this. See https://unece.org/transport/dangerous-goods/ghs-rev11-2025.

The changes are summarised as:

  • provisions further clarifying the classification criteria for aerosols and chemicals under pressure (chapter 2.3);
  • new guidance for classification for skin sensitization using non-animal methods (chapter 3.4);
  • classification for substances and mixtures that are hazardous by contributing to global warming (chapter 4.2);
  • further rationalization of precautionary statements to improve users’ comprehensibility while taking into account usability for labelling practitioners; and
  • a new section in annex 11 with guidance addressing identification of simple asphyxiants.

As usual, there may be other alterations which are hidden in the small print. My first thought was to obtain a copy of the pdf, and I was quite willing to pay, but it turns out that this is not available yet. Apparently the electronic free-to-download version will be published in September (although this will be a secured document), and I don’t know exactly when the unsecured, paid-for pdf will be released.

In the meantime, the UN have kindly provided a list of the amendments to GHS Rev 10 which will be brought across as GHS Rev 11, and you can find these here https://unece.org/transport/documents/2025/01/reports/amendments-tenth-revised-edition-globally-harmonized-system (although I did note at least one typo, of H331 instead of H311 for Acute Tox 3 dermal in the English language version).

Chemical snippets

Process Safety Corner

There have been quite a few incident reported this month, including:

Insights, this month all on “when safety systems can go wrong”:

Infographic of the Month

The best infographic I’ve seen explaining “the dose makes the poison” The dose makes the poison infographic.pdf (courtesy Allen Karpman, you can find his full post here: https://www.linkedin.com/posts/allen-karpman-93b7721_tfa-and-paracelsus-a-couple-of-years-ago-activity-7352026701696024576-x6t5) .

Like Allen, I have also been trolled by non-chemists claiming that “the dose makes the poison” is untrue, so it’s great to have an explainer that even the most chemophobic person can understand. Feel free to share Allen’s linkedin post or image with anyone you come across!

The Weekend Read

With the glyphosate issue being reopened by ECHA, I thought you might like Ashley Quigley CChem, MRSC ‘s analysis of the Ramazzini Study, here: https://www.linkedin.com/posts/ashley-quigley-bsc-hons-mrsc-78a41a157_glyphosate-glp-and-the-ramazzini-study-ugcPost-7346159938748002307-TqEJ

The Weekend Recipe

As it’s been fairly warm (at times, in between the rain), we are not using the oven, so when I realised that I needed some scones or similar, I thought that quite deep drop scones/ Scotch pancakes might be a reasonable substitute.

A quick internet search brought up a different recipe to the usual ones I use, and as luck would have it, their instructions used a smaller amount of milk to start with, then “add the milk to suit your preferences”. The good news is that when I used the smaller weight of milk, the pancakes turned out really deep and fluffy, just what I was after as a vehicle for home-made lemon curd and whipped cream. As I said to Mike, the main reason they worked so well is the extra baking powder. So this is the “hacked” recipe for very fat and fluffy drop scones.

Fat and fluffy drop scones ingredients

  • 125g (1C) Self Raising Flour
  • 1tsp Baking Powder
  • 1/4tsp Salt
  • 50g (1/4C) Caster Sugar
  • 1 Egg
  • 100 g Milk

Method – mix the dry ingredients together in a mixing bowl with your balloon whisk or fork and make a well in the centre. In a separate small bowl, beat the egg and weigh in the milk and mix together. pour the wet ingredients into the well and draw the flour etc in from the sides. Heat your frying pan with a tiny amount of oil or oil plus butter until hot enough for a drop of water to spit and run around the surface. Blob a couple of generous tablespoonfuls onto the pan, to make 2 pancakes, and wait for the bubbles to burst in the centre, then flip over until done on the other side.

This makes a thick batter which needs to be spooned onto the griddle, and it means that the scones take longer on the griddle/ very lightly oiled frying pan, but we were very pleased with them. The yield was about 7 to 8 pancakes, rather than a predicted 16 to 20, but well worth it. They did remind me of a school friend’s mother’s drop scones, which were deeper and fluffier than normal, so I think I’ve stumbled on her secret over 50 years later! As usual, keep them warm in a tea towel (helps keep them moist as well). These reheat nicely in the microwave (about 30 seconds per pancake, ours is 850 Watts).

Irony alert – the original recipe is from a website called “Scottish Scran” run by a New Zealand ex-patriate living on Skye: https://scottishscran.com/drop-scones-scottish-pancakes-recipe/ . Although as Scot living in Yorkshire, I could also be accused of cultural appropriation of Yorkshire recipes 🙂 !

Reasons to be Cheerful

This month, I thought we’d go with some modern comedy, from Joe Lycett:

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 August or early September.

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/

Table of Contents