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Chemicals Coffee Time Monthly, October 2025

Dear Reader,

It’s been a busy month, although we are still waiting for information on REACH 2.0 from the EU, and UK-REACH here in the UK, so let’s get started.

PPE news – new standard EN ISO 16231 to replace EN 166

If you use any type of eye protection, (safety specs, goggles, face masks), you may be used to seeing EN166 on them, or notes in section 8.2 of the SDS referring to eyewear which meets this standard. However, from mid November, EN 166 is being withdrawn, to be replaced with EN ISO 16231.

The British Standards Institute have a good blog about the changes you can expect to see (pun intended!): https://www.bsigroup.com/en-GB/insights-and-media/insights/blogs/a-new-era-in-eye-protection-understanding-en-iso-16321/

One of our lovely CLP Fastrak trainees was concerned about the references to EN 166 in her SDSs, and asked whether she should reissue them with the new EN 16321 instead. I think that it isn’t necessary to do this simply for a change in PPE standards, and checked with the regulations to confirm my hunch.

REACH Article 31 Requirements for safety data sheets, Paragraph 9 states:

Suppliers shall update the safety data sheet without delay on the following occasions:

(a) as soon as new information which may affect the risk management measures, or new information on hazards becomes available;

(b) once an authorisation has been granted or refused;

(c) once a restriction has been imposed.

So I would update existing SDSs with this new standard number when I’m doing a routine update (e.g. every 2 years or whenever you check your SDSs), or include the change if a more urgent update is required in the meantime.

Hearing from the HSE, DEFRA and the UK

GB-CLP updated to Version 7

Kathryn Tearle of British Coatings Federation broke the news thatVersion 7 of the GB MCL list has been published, see: https://www.hse.gov.uk/chemical-classification/classification/mcl-list.htm. As usual, the GB-MC List is in the format of an excel file to download direct to your device.

She notes: Some very high level analysis for you

The update includes substances which were assessed under:

  • Article 37A procedure (bixlozone, Solvent Violet 13, Pigment Red 83) – but one of these (bixlozone) is also on the 23rd ATP. Solvent Violet 13 and Pigment Red 83 do not have entries on Annex VI.
  • 18 substances on the update are on the 18th ATP to EU CLP
  • 10 substances on the update (including bixlozone) are on the 23rd ATP.

I have noticed divergence for bixlozone (Acute M-factor) and dinitrogen oxide (Reproductive Toxicity).

I have also noted some discrepancies with the GB Reports and the GB MCL update – dibenzyl peroxide – chronic M-factor – 1 or 10? – MCL list has M-chronic as 10 which agrees with the 22nd ATP, but the reports spreadsheet has 1. n-hexane retains the SCL in the GB MCL list, but reports agree to remove this.

Many thanks to Kathryn for this important information, and it’s interesting to note that the differences between the Technical Reports and the actual MCL classification are all making the MC agree with the existing EU Harmonised Classifications.

OPSS call for evidence – endocrine disruptors in cosmetics

Alison Potts of WSP notes that the UK’s Office for Product Safety and Standards has issued a call for data on Endocrine Disruptors in Cosmetics, which covers:

  1. Benzophenone-1 (CAS 131-56-6)
  2. Benzophenone-2 (CAS 131-55-5)
  3. Benzophenone -4 (CAS 4065-45-6)
  4. Benzophenone-5 (CAS 6628-37-1)
  5. Ethylhexyl methoxycinnamate (CAS 5466-77-3/83834-59-7)
  6. Triphenyl phosphate (CAS 115-86-6)
  7. Butylated hydroxyanisole (CAS 25013-16-5)

The consultation is open until 31st March 2026, and the full details are here: https://www.gov.uk/government/news/call-for-data-safety-of-cosmetic-ingredients .

Many thanks to Ali for spotting this.

Keeping an Eye on ECHA and the EU

EU-CLP new label format changes delayed

Earlier in October, we broke the news that the European Parliament have voted to accept the European Commission’s “stop the clock” proposals. For CLP, this extends the deadline for bringing in the much-disliked label format changes until 1st January 2028.

The vote results themselves (in French) are here: https://www.europarl.europa.eu/doceo/document/PV-10-2025-10-23-VOT_FR.pdf

And the official press announcement is here: https://www.europarl.europa.eu/news/en/press-room/20251017IPR30990/classification-labelling-and-packaging-of-chemicals-meps-agree-to-delay-rules

There may be some more bureaucracy to go through, but effectively it means that label formats can stay as they are now in the EU. Good news for the EU and NI, and also for GB companies selling into the EU (and vice versa) where a dual CLP label is being used.

The other good news is that this is not just a delay to allow industry more time to comply. It is specifically designed to give the regulators time to remove the label format changes from EU-CLP entirely.

The reason this compromise move was needed is because of the length of time it takes to alter EU regulations. It’s a lot quicker to move deadlines back than it is to actually alter the regulatory text. If the EU had tried to alter the text, the deadlines for implementing the new label format requirements would have kicked in, and then they would have been removed some time later, which would have been an un-necessary expense for industry.

So we should expect more changes to EU-CLP to remove the format requirements. The details of the EU Commission proposal are here: and their proposal is to replace the text with this wording:

So you are not under any obligation to change your labels to the new EU-CLP format (black text on white background, minimum font sizes, 120% spacing between row height etc), and we expect that these proposals will be going soon (not that anything to do with the CLP regulation is particularly quick).

Many thanks to our lovely newsletter readers who let me know the vote was taking place.

However, it’s not just the label formatting proposals which have been delayed

Gill Pagliuca of Ricardo notes on LinkedIn

“The postponed measures include: – Six-month deadlines for significant label updates – Mandatory formatting requirements for labels – Advertising and distance selling obligations – Labelling rules for fuel pumps Publication of the final text in the Official Journal is expected in the next couple of months. “

Full post here: https://www.linkedin.com/posts/gill-pagliuca-31812711_this-afternoon-the-european-parliament-passed-activity-7387118883620569089-U3z2

Many thanks to Gill for adding the extra information about which parts of CLP beyond the label format are being delayed.

Gill also has a more cautious approach to the removal of the labelling proposals (perhaps she is more cynical than me, or more experienced in the ways of the Eurocrats!) as she also writes “Whether these provisions will then be “rolled back” as suggested in the second proposal remains to be seen. For now, however, businesses can take a moment to regroup before these changes come into force.”

The up-to-date C&L inventory is now only available at ECHAChem

Have you noticed that the information about the ECHAChem website (https://chem.echa.europa.eu/) which sits at the top of the chemical search page of the ECHA website (here: https://echa.europa.eu/information-on-chemicals ) has altered recently?

It now says: The old C&L Inventory will be updated daily until 30th Sept 2025. Note that the old ‘Registered substance factsheets’ have not been updated since 19 May 2023. REACH Registration and C&L Inventory data will be removed from here by the end of 2025.

It would be nice to think that the ECHAChem website’s issues will be resolved by the time the REACH dossiers and C&L inventory are removed from the main ECHA website, but I’m not sure they will be.

Farewell to the Brief Profile

While we’re on the topic of the REACH dossiers I’m a massive fan of the Brief Profile, as it pulls data from the dossiers and displays it in a nice neat package (ideal for use in SDSs, e.g. where you are importing mixtures and want to use data for component substances).

It’s even got it’s own explanation that it “summarizes the non-confidential data on substances as it is held in the databases of the European Chemicals Agency (ECHA), including data provided by third parties“. So you can’t be prosecuted for breaching copyright if you use Brief Profile data.

I’ve just discovered that “The Brief profiles will be removed from ECHA’s website by the end of 2025. All the information from REACH registrations the C&L Inventory are already available in ECHA CHEM.”

A further search brings up the ECHAChem migration page https://echa.europa.eu/echa-chem, which confirms that the Brief Profile will not be available on ECHAChem.

This is a real pity, as it saves a lot of time digging into the data sections of REACH dossiers.

REACH 2.0 delays

Ali Potts also writes: I can confirm that the Caracal meeting (where the draft legal text of REACH 2 was expected to be shared) was cancelled! Indicating that the legal draft is delayed. I am continuing to follow this as closely as possible.

Thanks again to Ali for keeping an eye on this for us.

There is also an opinion piece from Enviresearch on the likely causes of the delay to EU-REACH 2.0, https://www.enviresearch.com/news/further-delays-are-expected-to-eu-reach-revision/

Process Safety Corner

Recent incidents

Insights

Infographic of the Month

Official government elf’n’safety madness map – another great poster from the HSE (thanks to Sean Moran CEng FCIWEM for sharing this on LinkedIn) https://assets.publishing.service.gov.uk/media/5a7b8c8840f0b645ba3c508f/elf-safety-map-251113.pdf

The Weekend Watch/ Read

And some real life lab accidents we can learn from – https://www.linkedin.com/posts/steve-macdonald-brown_talesfromthebench-processsafety-labsafety-activity-7376144579462590465-KZ3Z

The Weekend Recipe

Did you know that there was World Porridge Day on the 10th of October? me neither! But it was a good excuse to bring out a flapjack recipe I’m rather partial to, Ginger Flapjack. (Note to any American readers – flapjacks in the UK are oat-based biscuits, not pancakes).

Ginger flapjacks

Flapjack Ingredients

  • 8 oz rolled oats. I prefer the ones which are quite broken floury (traditional Scotts porage oats),. If you can only get hold of whole rolled oats, break them up by hand or even whizz them in a blender or spice grinder to get the same texture)
  • 6 oz butter
  • 4 oz demerara sugar (ideally, although granulated sugar will do at a pinch)
  • 1 tablespoon golden syrup
  • 2 level teaspoons ground ginger

Ginger Icing ingredients

  • 6 oz butter
  • 4 tablespoons golden syrup
  • 7 oz icing sugar
  • 2 level teaspoons ground ginger

Method

Set your oven to Gas mark 3 or 4, depending on how “quick” your oven is. Grease an 8 inch/ 20 cm sponge tin, or a similar sized square or rectangular tin (you could line it with greaseproof paper or foil sticking up the sides to make taking the flapjack out easier). This size of tin makes quite a thick flapjack, if you want a thinner version use eg a 10″ by 7″ rectangular tin.

Make the flapjack by melting the butter, sugar and golden syrup together in a a large pan over a low heat, then stir in the ground ginger and rolled oats. Press firmly into the tin, and smooth with the back of a spoon. Bake for 20 to 30 minutes and leave to cool in the tin.

Meanwhile make the ginger icing. Melt the butter and syrup together in a pan over a low heat. Stir the icing sugar and ginger together to mix thoroughly. Once melted, stir in the icing sugar/ ginger mix and leave to cool.

When completely cool, either leave the flapjack in the tin, or remove, and cover with the topping. If the topping is still a bit warm, you may be able to pour it over the flapjack, otherwise spoon it over and smooth out. Enjoy!

Free from options: if you swap the butter for margarine, this recipe become vegan and lactose free. If you are gluten intolerant, you can make this with gluten-free oats as well.

Reasons to be Cheerful

This month we had a series of funny videos from Armstrong & Miller:

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 November or early December.

Kind regards,

Janet

Janet Greenwood, TT Environmental Ltd

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