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Chemicals Coffee Time Monthly, March 2026

Posted
Updated
ByEmma

Dear Reader,

It’s been another busy month for regulation, and we have numerous consultations to participate in. But first, some breaking news on UK-REACH.

Breaking News – UK-REACH ATRm

As predicted by Clelia Oziel in her post last week, the UK Government published their responses to the UK-REACH consultation on the ATRm on the 30th March 2026 at https://www.gov.uk/government/consultations/an-alternative-transitional-registration-model-atrm-for-uk-reach/outcome/summary-of-responses-and-government-response.

There’s a good initial summary from Steven Brennan here: https://www.linkedin.com/posts/dr-steven-brennan_summary-of-responses-and-government-response-activity-7444683578011082752-hM4w.

There are obviously many details which need to be sorted out, but it gives an overview of where UK-REACH is headed.

Hearing from the HSE, DEFRA and the UK

UK-REACH amendment #1

Caroline Raine was the first to spot the new GB lead restriction in ammunition – https://www.legislation.gov.uk/uksi/2026/195/contents/made

It brings the EU-REACH restriction on lead ammunition for sporting purposes into effect in the UK, which was started pre-Brexit, so we have been expecting it for some time.

“must not be used or placed on the market after 1 April 2029— (a) in a concentration equal to or greater than 1% by weight in shot; (b) in a concentration equal to or greater than 3% by weight in other projectiles“

There are a few exemptions for high level (Olympic) shooting athletes, but live quarry shooting using lead shot or bullets will be banned.

Ironically, some EU countries are starting to realise that lead is the best option for shotgun shooting of live quarry, (from the perspective of animal welfare), and there is talk about reversing this policy.

UK-REACH amendment #2

There has also been a second (draft) amendment on UK-REACH altering some deadlines, see https://www.legislation.gov.uk/ukdsi/2026/9780348281613

UK Consultations

UK-REACH SVHCs

Since Brexit, the UK has not issued any new SVHC proposals, while the EU has added many more substances. However, we now have 15 SVHC proposals, with each consultation ending on the 26th April 2026, so not long to comment on:

UK-EU Sanitary and Phytosanitary Agreement

Not technically a consultation, but a request for information/ feedback on the UK-EU SPS agreement https://consult.defra.gov.uk/eudp-evidence-and-analysis/uk-eu-sps-agreement-call-for-information/ .

A reader writes: The Government has announced the list of EU legislation that is considers in scope of the negotiations. The legislation which may come as a bit of a surprise is BPR.

Full list is at https://www.gov.uk/government/news/uk-eu-sps-agreement-legislation-in-scope, including BPR and food contact regulations along with pesticide regulations and other animal and food legislation.

If your business is affected by this, then do participate in the feedback process, which ends on the 23rd April 2026.

UK POPs regulation update

UK updates to the POPS regulation consultation https://www.gov.uk/government/consultations/amendments-to-the-persistent-organic-pollutants-pops-regulation-2026 (Hat tip Amy Fearon of WSP for highlighting this).

The proposals include new substances:

  • Medium-chain chlorinated paraffins (MCCPs)
  • Long-chain perfluorocarboxylic acids (LC-PFCAs)
  • UV-328
  • Dechlorane Plus (DP)
  • Chlorpyrifos

There’s also a proposed amendment to the existing PFOS entry.

The consultation ends on 13th May.

Keeping an Eye on ECHA and the EU

Detergents Regulation

Kath Duckett of STADA Thornton & Rosssent through the news that the EU detergents regulation is published – https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ%3AL_202600405

Harmonised Classification news

The EU is about to propose moving substances from the SVHC list, Biocides and Plant Protection Products directly into the Harmonised Classification list. We have been expecting this for SVHCs which have been given that status because they have the new hazard classifications (e.g. endocrine disruption) but it looks like this will be a wider programme than initially thought.

Steven Brennan of Foresight has been sent a link to the relevant CIRCABC page here: https://circabc.europa.eu/ui/group/a0b483a2-4c05-4058-addf-2a4de71b9a98/library/3a42dc10-5b2a-493b-8c71-ed8aeafb6444/details, where you can download the full list of proposals as an “early warning”.

Steven has also made a great summary of the proposals here: https://www.linkedin.com/posts/dr-steven-brennan_circabc-activity-7439602868178972672-_IeH. And don’t forget his excellent weekly newsletter.

EU consultations

Benzotriazole and Tolyltriazole CLH

Mick Wragg writes – ECHA has opened consultations for revised harmonized classifications for benzotriazole(BTZ) and tolyltriazole(TTZ).

Both substances are already listed on CLP Annex VI as Aquatic Chronic 2 (Delegated Regulation 2024/2564) with legal deadline for EU suppliers of 1st May 2026. What’s unusual about this in my opinion is that these substances were only recently subject to CLH review by RAC (in 2022), following an initial CLH proposal by BAuA so this is a fairly quick turnaround for another, more severe hazard evaluation:

  • methyl-1H-benzotriazole [1] and its inorganic salts, with the exception of those specified elsewhere in this Annex (EC 249-596-6 [1], CAS 29385-43-1 [1])BAuA proposal is Add Repr. 2 Acute Tox. 4 PMT vPvM Retain Aquatic Chronic 2
  • 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])BAuA proposal is Add Carc. 2 Repr. 2 Acute Tox. 4 ED ENV 1 PMT vPvM Retain Aquatic Chronic 2

Consultations close on 4th May.

Alison Potts of WSP adds – ‘Benzotriazole’ and ‘Tolyltriazole’ are absolutely huge substances with at least 10 registrants with tonnage at or above 1000 tonnes per annum.

They are used in aeroplane de-icing fluids, hydraulics, lubricants and in coolants where their anti-corrosion properties are key. And, crucially, they don’t have viable alternatives.

If you look at the alternative chemistries in use, they have their own health and environmental concerns or are less effective or ineffective against certain materials and chemistries. Often meeting the definition of ‘regrettable substitution’.

There are no easy answers here. If the reported health and environmental toxicity results are correct, then clearly regulatory intervention is required. But this one is going to cause upheaval! The usual plea from me to contribute to the EU consultation if this affects you as there will not be a separate UK consultation process.

Many thanks to Mick and Ali for spotting these important consultations, which you can find here: https://www.echa.europa.eu/harmonised-classification-and-labelling-consultation

Glyphosate targeted CLH proposal

There is a separate “targeted” consultation on whether glyphosate should attract a carcinogenicity classification which is also open at ECHA until the 31st March, see https://echa.europa.eu/harmonised-classification-and-labelling-targeted-consultations/-/substance-rev/81310/term

SEAC consultation on PFAS

You may have missed the RAC publishing its final opinion on the definition of PFAS in the EU, which came out on the 2nd March.

This includes an important change to the proposed definition of PFAS, which is key to the impacts on industry:.

(quote) Per- and polyfluoroalkyl substances (PFASs) defined as: Any substance that contains at least one fully fluorinated methyl (CF3-) or methylene (-CF2-) carbon atom (without any H/Cl/Br/I attached to it).

The Dossier Submitter proposes to exclude the following substances from the scope on the grounds that they are fully degradable: “A substance that only contains the following structural elements is excluded from the scope of the restriction: CF3-X or X-CF2-X’, where X = -OR or -NRR’ and X’ = methyl (-CH3), methylene (- CH2-), an aromatic group, a carbonyl group (-C(O)-), -OR’’, -SR’’ or –NR’’R’’’; and where R/R’/R’’/R’’’ is a hydrogen (-H), methyl (-CH3), methylene (-CH2-), an aromatic group or a carbonyl group (-C(O)-).” (quote ends).

However, the RAC have commented (page 14) : RAC considers that the evidence provided is not sufficient to justify this exclusion (see section 3.1.1. of the RAC Opinion).

Including fully biodegradable substances tightens the scope of the restriction significantly. As this is the RAC’s “final opinion”, it may not be open to challenge.

It means that derogations will only be available on the basis of product use, and not on the basis of chemistry.

However, the SEAC consultation which is open at the moment, does provide an opportunity to comment on the situation, see https://ec.europa.eu/consultation/runner/echa_pfas_seac_do_consultation

Chemical snippets

Events

Can you help?

James Stone, of the ChemUK team, is running the London Landmarks Half Marathon to raise money for Blood Cancer UK on the 12th April, and if you’d like to donate to this excellent cause, you can do so here: https://www.justgiving.com/page/james-stone-1993 .

The good news is that his Mother, Jini, is recovering steadily after receiving a stem cell transplant before Christmas, but it is a long slow journey for her and all of the Stone family. We wish them all the best.

Process Safety Corner

Recent incidents:

Insights:

Infographic of the Month

Real life vs Linkedin posts https://www.linkedin.com/posts/chris-collins-57887514_activity-7423540335554924544-K2xT

The Weekend Watch/ Read

Jen Novakovich on why food products may not be safe as beauty products – https://www.linkedin.com/posts/activity-7434647755286802433-E7HB/. An important watch for everyone (even chaps – your female relatives may not realise the dangers). Please share this video with anyone who needs to hear its message.

The Weekend Recipe

It’s traditional to think of lambs in the spring and around Easter, but at the same time the weather is quite unpredictable, so what better than a recipe to an excellent lamb curry?

Julie Bailey’s lamb curry

  • Diced lamb (as much as you like)
  • 1 large red onion
  • 400ml tin of chopped tomatoes
  • 2 -3 cm of ginger finely chopped
  • 3-4 cloves of garlic finely chopped
  • One red chilli finely chopped (use more or less depending on how hot you like your curries)
  • 1 table spoon of medium curry powder
  • 1 and a half tea spoons or garam masala
  • 1 lamb oxo cube
  • 200ml of water

Method

  • First of all brown your diced lamb off and set to one side ( use as much lamb as you like)
  • In a large pan fry one large red onion in oil until brown
  • Next take your ready chopped tinned tomatoes, ginger, garlic and red chillies and add them to the pan
  • Now add your medium curry powder, garam masala and lamb oxo cube
  • Add a little salt for seasoning.
  • Transfer the contents of the pan to a large casserole pot (or something similar) and add the lamb and 200ml of water and stir
  • Give a good stir and pop into the oven on 1300c- 1500cfor around 6-8 hours (best things to those who wait)
  • The lamb will now be lovely and tender and ready to serve with some rice

Findings: This is a truly excellent recipe and can be made in the oven or a slow cooker. I usually use about 2lbs of shoulder of lamb for this. It freezes well.

Reasons to be Cheerful

We had a series of 8 out of 10 Cats does Countdown videos in March:

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 April or early May.

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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