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Chemicals Coffee Time Monthly, September 2025

Posted02/10/2025
Updated02/10/2025
ByEmma

Dear Reader,

During September, we waited (in vain) to hear about the proposals to push back the UK-REACH registration deadlines further; and also to hear about the REACH II proposals in the EU, particularly what’s happening with polymers. There was still plenty to keep us occupied though!

Hearing from the HSE, DEFRA and the UK

Explosives precursor and Poisons regulations reminder

If you’re struggling to deal with a whole pile of supplier or customer questionnaires (or your purchasing department is), you might think that a form asking for your identity is just another piece of bureaucracy.

But if it’s about something which is a Poison, or an Explosive Precursor, it’s actually a legal requirement for your supplier to request this information, and you need to comply with it (it’s anti-terrorism law, not chemicals regulation per se). Not only that, but there is a requirement to make these checks every 18 months.

Part of the problem is that this requirement sits within 3 separate pieces of regulation:

There is guidance for suppliers: https://www.gov.uk/government/publications/supplying-explosives-precursors/supplying-explosives-precursors-and-poison

The current list of affected chemicals is here: https://www.gov.uk/government/publications/supplying-explosives-precursors/list-of-chemicals, and there is a list of all the guidance documents here: https://www.gov.uk/government/collections/hazardous-sites-and-substances

Safe handling of chemicals poster

Did you know the HSE have an excellent poster on the safe handling of chemicals? You can buy hard copies https://www.hse.gov.uk/pubns/chemicals-poster.htm or download the pdf for free and print your own: https://www.hse.gov.uk/pubns/priced/chemicals-poster.pdf .

I can’t believe I didn’t know about this sooner, as it’s been around since 2019.

Tea tree oil classification still under review in GB

An interesting article on this https://www.linkedin.com/posts/thegreenchemist_teatreeoil-naturalingredients-cosmetics-activity-7366763632539426818-vnBH

“The UK HSE has decided not to classify tea tree oil as a CMR 1B reproductive toxicant — a clear divergence from the EU position. Instead, tea tree oil will be reassessed under Article 37A of GB CLP, so its future is still under review“.

It will be very interesting to see what the HSE technical team think about this, particularly as they made the correct decision on Titanium Dioxide.

Keeping an Eye on ECHA and the EU

Confirmation of a pause on the EU-CLP label formatting proposals

“This proposal (the so-called ‘Stop-the-clock’ mechanism) postpones to 1 January 2028 the date of entry into application of the revised regulation on classification, labelling, and packaging of chemicals (CLP regulation). The proposal also amends the timelines for relabelling, mandatory formatting requirements, advertisements, distance sales and labelling of fuel pumps”.

We understand that this postponement is to allow time for legislators in the EU to take the EU-CLP label formatting proposals completely out of CLP, to be replaced with a bland statement along the lines of “the label should be clear and legible”.

Titanium Dioxide hazard classification removal update …

In case you missed it, a recent ECHA newsletter includes the following information on Titanium Dioxide:

“Following the European Court of Justice’s ruling of the classification of titanium dioxide, we have updated the relevant information on our websites.

The harmonised classification has been removed from the C&L Inventory and the registry of intentions has been updated. We have also deleted ECHA’s guide on classification and labelling of titanium dioxide from our website.

The ruling of the European Court of Justice to annul titanium dioxide’s classification is effective from 1 August 2025.”

I understand that the relevant information they are referring to is the Harmonised Classification of Titanium Dioxide. Removing this HC clarifies the position for European industry, and anyone selling into the EU.

Removing this Harmonised Classification may also remove the EUH statements which were brought in by it, that is EUH211 and EUH212, and Notes V and W to the HC list, but we may need to wait for the next consolidated version of CLP for confirmation of this.

…but Titanium Dioxide still under review for Cosmetics

Just when we think that Titanium Dioxide is innocent of all charges, up crops another charge – that it may be carcinogenic in cosmetics. Steven Brennan writes on Linkedin:

“The European Commission has formally requested a fresh SCCS Opinion on the safety of Titanium Dioxide (nano and non-nano) in oral cosmetic products”. More details here –https://www.linkedin.com/posts/dr-steven-brennan_sccs2022q041-activity-7376281578551001088-ebP4

They are specifically considering nanoparticle risks and are concerned about toothpaste – but I thought that people aren’t supposed to swallow toothpaste because of the (known) risks of fluoride?

Many thanks to Steven for spotting this, and sharing it with a wide audience (you can sign up to his newsletter here: https://www.linkedin.com/newsletters/7165705027863429120/ and follow him on LinkedIn here: https://www.linkedin.com/in/dr-steven-brennan/ )

ECHA Chem changes

Have you spotted the changes on the ECHACHem website? There are two new search boxes on the home page covering “legal obligations” and “regulatory activites”.

These new items were discussed in an ECHA webinar on Tuesday, 23rd September,hosted by Heidi Rasikari, who runs the very useful ECHA PCN linkedin group . and the recording is now available here: https://www.echa.europa.eu/-/echa-chem-first-set-of-regulatory-process-and-obligation-lists

Around the World

The REACH concept is reaching even further.

Melissa Owen has news of Colombia and Chile REACH https://www.linkedin.com/posts/melissa-owen_melonlatam-reach-chemicals-activity-7369165413747712000-Ljbh, and even Bolivia is considering something along those lines, even though it hasn’t adopted GHS yet, see https://www.linkedin.com/posts/melissa-owen_ghs-chemical-latinamerica-activity-7369293156774789125-2lEP; and her latest newsletter is here: https://www.linkedin.com/posts/melissa-owen_reach-chemicals-criticalminerals-ugcPost-7368397423905288196-r7J3

Is it just me, or can you hear the Red Weed theme tune from War of the Worlds as REACH-style regulations threaten to strangle chemical trade?

Process safety corner

Recent incidents:

Insights :

Events

ChemUK News

In a surprise move, CHEMUKEXPO announced that they have now transferred ownership of ChemUK to EasyFairs, see https://www.easyfairs.com/2025/09/22/easyfairs-acquires-chemuk-to-further-unite-the-uks-chemical-sectors/ .

The current management team will be in place for ChemUK 2026, (NEC, Hall 5, on the 20th & 21st May 2026) which looks like an even better event than last year. The Chemical Regulations Self Help Group will be on Stand H160, thanks again to Ian Stone his team for supporting us, and I hope to see you there.

A few days later, we also learned that Jini Stone , Ian’s wife, has retired as Managing Director ChemUK as she is battling blood cancer, and we wish her all the luck in the world. More on Jini’s story here: https://www.linkedin.com/posts/istone_team-jini-fundraising-for-blood-cancer-uk-activity-7378838485383737344-mHXA

If you have benefited from ChemUK (as many of us have), and would like to support Jini, Ian and all their family and colleagues, there are a couple of ways to help:

Event #1

CIA and Steptoe are publicising their excellent one-day chemical conference Chemical Reactions, which takes place on Thursday, October 16th 2025 in Manchester, see https://www.steptoe.com/en/events/chemical-reactions-uk-chemicals-conference-2025.html.

To say the chemical regulatory landscape is fluid at the moment is an understatement, and there’s a truly excellent line up of speakers who can assist industry in getting to grips with things:

Event #2

Did you know that DGSAs are required to investigate incidents involving Dangerous Goods, but there is very little advice on how to actually do this? Our friends at BADGP are filling in the gaps with a webinar on the 7th October 2025 13:00 – 14:30 BST, https://badgp.org/event-6339150 (free for BADGP and CHCS members)

Event #3

OK, this is not technically a event, but our CLP Mastery training course starts again on Wednesday 8th October, and if you’d like an invitation to join us, please send me a direct message. Further details here: https://clpmastery.com/

Infographic of the Month

Labels in the lab https://www.linkedin.com/posts/nicholas-s-edmond_seems-reasonable-activity-7371071179786178560-BL_c

The Weekend Watch/ Read

An excellent post on LinkedIn from Gabi Buttner on the problems with CLP currently being a hazard based system and not a risk based one – https://www.linkedin.com/posts/gabi-b%C3%BCttner-4843591b9_chemicalcompliance-ethanol-titaniumdioxide-activity-7376118621745455104-pLFk

Unfortunately, this problem comes from GHS, which is the main parent of CLP, and until this is changed to a risk-based system, these problems will continue. (There are many other problems with GHS, but this is one of the most fundamental ones).

The Weekend Recipe

A lot of people have been complaining about a lack of field mushrooms, but Mike and I have been lucky with them this year. We picked an absolute monster a couple of months ago about half a mile from home, which did us two meals, and the recent rain seems to have brought more local field mushrooms out. (I need hardly add that if you are foraging for mushrooms, make sure you know exactly what you are picking, as many fungi are “only edible once”, as the late Terry Pratchett observed). After we’d picked a good amount, I made mushrooms on toast for tea (not unlike the old Heinz Toast Toppers we oldies remember).

Ingredients:

  • a quarter of a small onion, very finely chopped
  • Mushrooms (field mushrooms or cultivated ones)
  • OIl and butter for frying
  • Double cream
  • Toast (seeded or brown for preference).

Method: first chop your onion very finely (you need a couple of teaspoonsful or so), and chop up your mushrooms into bite sized chunks. If you are using the stalks, chop these more finely. In a frying pan or wok, heat the oil up and add a good knob of butter, then add the onion and fry for around 5 to 7 minutes until done. Then stir in the mushrooms (stalks first for a couple of minutes, then add the caps) and cook until they have reduced in size. A slight sprinkling of salt and pepper is advisable. You may find you get a lot of liquor at this stage, which you may want to boil off mostly (but don’t boil it all off).

Meanwhile pop your bread on to toast. Add a bit of double cream to the mushrooms, and stir thoroughly. Gently bubble to get to a good texture. Serve the creamy mushrooms on toast, and bask in the nostalgia!

Reasons to be Cheerful

This month, I have discovered some more Don McMillan videos:

And you may like this funny sign from our friend Tracey Hemingway-Wright at Hibiscus: https://www.linkedin.com/posts/traceyhemingwaywright_caution-activity-7371542289715867648-59WE

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 October or early November

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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