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Chemicals Coffee Time Monthly, November 2025

Posted
Updated
ByEmma

Dear Reader,

November was a busy month, topped off by important news on the EU-CLP regulation “stop the clock” proposals in early December, so I’ll start there.

“Stop the Clock” on EU-CLP passed

The CLP “stop the clock” regulation was published on 3rd December 2025 in the Official Journal:

Many thanks to Caroline Raine for sharing this news. She writes – it postpones the timelines for some changes from CLP revision in 2024 that are also addressed in omnibus (advertising, formatting rules, distance sales, refill stations, label updates) to 1 January 2028.

As the regulation “…shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Union. This Regulation shall be binding in its entirety and directly applicable in all Member States.”, that means it comes into immediate legal effect on the 23rd December 2025.

Although the intention of the “stop the clock” for CLP was to buy time to allow the formatting rules to be made much simpler, there are signs that this initial intention may be subverted, and that there may be further changes to the label format – watch this space!

Hearing from the HSE, DEFRA and the UK

BPR update for GB

Nicola Kaye of BASF writes: This SI has now been been published and comes into force on 30 December 2025 extending the data protection period until 31 December 2030 under GB BPR for active substance / product type combinations for which no decision has been issued.

Many thanks to Nicola for sharing this important news with us.

Authorisation list in UK

In a first for UK-REACH, the HSE are recommending that 3 substances should be authorised under UK-REACH:

Full details here: https://content.govdelivery.com/accounts/UKHSE/bulletins/3fa1b85

Tetra ethyl lead notes

Steve George of SG Advisory Services Ltd wrote in to say:

On TEL, yes it has gone from petrol for general use, but there are exemptions. it is still used by some classic cars though alternatives are generally available, or adaptations to piston valves that can be made. The big one however is general aviation – small propeller driven aircraft, such as crop dusters…. Think wide dispersive use! In the EU, Applications for authorisation for continued formulation and use in the EU/EEA/NI area have been reviewed by ECHA, with a 7 year review period recommended.

Trevor Mathers of Alfa Chemicals writes: on the subject of tetraethyl lead, I learned a few weeks ago that the same inventor who came up with TEL at General Motors, Thomas Midgley https://en.wikipedia.org/wiki/Thomas_Midgley_Jr., was the same inventor who discovered CFCs! Clearly a very capable inventor, even if the unintended consequences mightn’t make him a hero…

Tea Tree Oil in GB update

Lizi Jenkins of Future Regulatory Services has passed this information along from the CTPA: CPTA Members will be aware that Tea Tree Oil (TTO) is going through the mandatory classification process under the GB Classification, Labelling and Packaging (CLP) Regulation. One of the initial proposed classifications by the Health and Safety Executive (HSE) was CMR 1B (reprotox); however, in its Final Opinion, the HSE removed the CMR 1B proposal from the Article 37 process and this specific classification proposal will be managed through an Article 37A process of GB CLP, which will be launched soon. The Article 37A process includes a public consultation to allow industry and other stakeholders to submit additional evidence to further inform the classification proposal. Please see the HSE final opinion on tea tree oil here and more information on the status of TTO is available on the relevant page of the CTPA Ingredients Hub.

Many thanks to Lizi for sharing this with us.

Keeping an Eye on ECHA and the EU

Ethanol and BPR decision delayed

Regular readers will remember that there is a scandal brewing over the potential CLP harmonised classification of ethanol as a carcinogen, on the basis of ingestion. This would potentially make it impossible to use it in cosmetics, and as a biocide.

As you might expect, there is significant industry concern over the potential withdrawal of such a good, cheap, widely available and efficacious biocide, see “Ethanol hand sanitiser madness” https://www.linkedin.com/posts/ojan-assadian-ba81a134_infectionprevention-echa-publichealth-activity-7389384218142920704-Iv-W and “Hands up for ethanol” https://www.linkedin.com/posts/jim-thomas-57a6a746_focus-on-ethanol-important-regulatory-developments-activity-7389925197463851010-6FM3.

AISE have also entered the debate: see https://www.linkedin.com/posts/a-i-s-e-international-association-for-soaps-detergents-and-maintenance-products_joint-statement-activity-7391463113931526145-klT4. As they point out, “The data being considered includes studies on alcohol consumption and abuse — not the use of ethanol in hand or surface disinfectants, which have been proven to be safe.

ECHA hasn’t explained why this data is relevant to biocidal use, even though the contexts are completely different. A classification based on drinking alcohol would not reflect real-world exposure of biocidal products and could have serious implications for public health if ethanol-based disinfectants become restricted.“

We were expecting some kind of regulatory compromise to allow ethanol to continue to be used as a biocide out of the ECHA BPC meeting on the 26th November.

However, it seems that the committee are unable to reach agreement on the best way to do this, so we have a postponement until 2026: https://echa.europa.eu/-/echa-s-opinion-on-ethanol-postponed-to-2026 .

One substance, one assessment

More news on the move towards “one substance, one assessment” from the EU: https://www.consilium.europa.eu/en/press/press-releases/2025/11/13/chemicals-council-greenlights-legislative-package-to-streamline-chemical-safety-assessments . I simply haven’t had time to go through this, but if you have any comments, please do let me know via DM.

Supply chain tracking – an early warning

What did we do before Steven Brennan set up Foresight with his colleague Jonny Campbell? we didn’t get half the early warning on the next lunatic ideas, sorry, set of incoming regulations from the European bureaucracy.

Steven writes – “The EU just quietly released a document that will change how supply chains track chemicals forever. The new JRC methodology for identifying and tracking substances of concern under the Ecodesign for Sustainable Products Regulation (ESPR) is not getting headlines, but it should be… This is a fundamental change in how supply chains will manage chemical information.”

Further details here: https://www.linkedin.com/posts/dr-steven-brennan_method-for-the-identification-and-tracking-activity-7399807352683646976-xiOh

I thoroughly recommend Steven’s newsletter: https://www.useforesight.io/newsletter, and he also has a full alert service for chemical policy worldwide: https://www.useforesight.io/get-a-demo-of-foresight.

Thanks to Steven for advance warning of what could clearly be another piece of extremely burdensome red tape.

Candidate (SVHC) list discrepancy between websites

Adam Lamb of Avocet Dyes and Chemical reports that CAS no 84852-53-9, which was added to the EU’s Candidate List (which gives SVHC status) on the 5th November to the “old” ECHA website (as a vPvB), is still not present on the ECHA Chem version of the list.

As Adam says, if people are only checking the new list, they may be unaware of the new inclusion, so please do check any information on the various lists on ECHAChem with the ones on the main ECHA website as well.

The situation is very confusing during this period of data migration between the main ECHA website (https://echa.europa.eu/) and ECHA Chem (https://chem.echa.europa.eu/).

Around the World

GHS committee meeting postponed

ICYMI, Kathryn Tearle of BCF writes, via the CHCS website (member’s area), that the 49th Session of the UN GHS Sub-committee of Experts which was due to be held in Geneva in December 2025 has been postponed until 8th (afternoon) to 10th July 2026

It’s not clear whether this will delay publication of the next Revision of GHS, or whether it will just be a busier meeting for the delegates.

Chemical snippets

Process Safety Corner

Recent incidents

Insights

Infographic of the Month

A useful infographic on Hazardous Area Classification https://www.linkedin.com/posts/mohamed-dweek-a282a745_insightful-conclusion-of-iec60079-hac-activity-7379935386116014080-D4ka/

The Weekend Watch/ Read

While we’re on the topic of Hazardous Area Classification, I thought you might like this very important read from Chris Cloney on dust explosion hazards – Can a few mm really cause a dust explosion? (spoiler alert, yes it can!) https://www.linkedin.com/posts/chris-cloney_𝗖𝗮𝗻-𝗮-𝗳𝗲𝘄-𝗺𝗺-𝗿𝗲𝗮𝗹𝗹𝘆-𝗰𝗮𝘂𝘀𝗲-ugcPost-7391810182693052416-Vlid

The Weekend Recipe

Ginger cake in a mug

For those times when you need a quick hit of cake, a mug recipe in the microwave is the answer, but I hadn’t seen a ginger cake recipe until recently (I hesitate to call it gingerbread).

Ingredients

  • 4 tbsp plain flour
  • 2 tbsp soft light brown sugar
  • large pinch of baking powder
  • large pinch of ground cinnamon, plus extra to serve (optional)
  • ¼ tsp ground ginger
  • 2½ tbsp milk (or non-dairy alternative)
  • 1 tbsp rapeseed oil

Method: in a small bowl, combine the flour, sugar, baking powder and spices. Whisk in the milk and oil until fully combined, then place in a microwaveable mug (250 ml size). Heat in a 750W microwave for 1-1½ mins until cooked through. Leave to stand for 1 min before serving.

Serving suggestion, serve with vanilla ice cream and a dusting of cinnamon.

Findings – this definitely needs to be eaten immediately, while it’s still warm, and using vanilla ice cream will help both the texture and flavour. Be careful not to cook it for too long.

Reasons to be Cheerful

In November, we had a selection of videos from Mitchell and Webb:

A personal Reason to be Cheerful

I was deeply honoured to receive honorary membership of the Society of Dyers and Colourists, https://sdc.org.uk/, at their Day of Celebration on Friday 14th November.

I’d been nominated for my work in setting up and organising the Chemical Regulations Self Help Group, but I also consider this honour to be for the whole group, not just me personally, as it is very much a team effort. Thank you very much to all CRSHG members, past and present.

There is a video of the day (awards session in the afternoon, and black tie dinner) here: https://www.linkedin.com/posts/shelley-hollingdrake-ma-53a25680_sdc-colour-community-activity-7397236697287196672-aMsK .

If you are interested in the work of the Chemical Regulations Self Help Group, our website is here: https://www.chemselfhelp.co.uk/ .

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 December or early January.

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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