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Chemicals Coffee Time, 6th October 2023

Dear Friend,

Happy Friday!

It’s been raining for a couple of days here. Meg, our old dog, really dislikes the rain these days (unless there’s some interesting scent about), as cocker spaniels only have a single layer of fur, so both dogs are in their rain coats this morning.

The good news is that the weather astrologers/ forecasters are predicting a range of higher temperatures, from 23 o C down to 16 o C for us over the weekend. I think we’ll believe that when we see it!

EU CLP Legislative Act European Parliament debate

Ali spend an “interesting” couple of hours this week watching the plenary debate and subsequent vote (and I was very happy to delegate that task!). Her first report was “If I’ve learnt anything today, it’s how important Rose Oil is to the culture and economy of Bulgaria“.

She then spent a couple of hours looking up the relevant documents and translating the various MEPs comments (because the auto-translation was a bit patchy) while she stewed over her conclusions. Before, ultimately deciding that she was highly amused by some of the completely clueless comments made in the debate that seemed to be wilfully ignorant of hundreds of years of basic science. I’ll hand this one over to Ali…

Hi everyone!

I will eventually get around to talking about the Legislative Act – but honestly, I need to talk about some of the ridiculous points made in the poorly attended plenary debate first! It was fairly one-sided, with almost all the speakers giving broad support for the reform of CLP. But the real sticking point was Essential Oils.

At least 3 speakers spoke at length about Bulgarian Rose Oil, whilst a French delegate spoke passionately about the Lavender fields of Provence. The Commission Representative expressed that the EC was paying ‘Special’ (repeat – ‘Special’) attention to the MEPs concerns about their ‘famous’ essential oils. The Vice-President and the Rapporteur both pointed out that they had visited workers in Essential Oil industries in Bulgaria and Spain to explain that the reforms did not intend to destroy their livelihoods.

There was a suggestion from the French representative that Products of Botanical origin be legislated completely separately from Products of Petrochemical origin. And agreement from multiple speakers that plant based substances are not ‘risky’ (direct quote)! To which I can only remind them that Digitalis, Ricin, Belladonna and a host of other toxins were not dreamt up in a lab.

I would like to give credit to Pietro Fiocchi, Italian MEP. (Although, I’m sticking a massive disclaimer in here because I know nothing about his personal politics and I don’t want to inadvertently support anything dubious.) He was the only representative who spoke about the impracticality of the new labelling requirements, and specifically stated that the writers of the legislation had clearly never worked a day in industry! Also pointing out the conflict between larger labels with more content and the EC’s aims to reduce paper, plastics and packaging.

In contrast, his compatriot Danilo Oscar Lancini, also an Italian MEP, chose not to use his debate time to actually discuss the CLP regulation. Instead, he gave a somewhat bizarre statement objecting to the participation of Industry Associations in the negotiation phase of legislation. He called out CEFIC and AISE for ‘playing politics’ and demanded that representation of small and medium sized businesses should be left to the MEPs that are democratically elected.

We at Chemicals Coffee Time advocate strongly for the Industry Associations and have commended them for picking up the baton on several key regulatory topics in recent years. The work of the TDMA on Titanium Dioxide, and the CBA on the revocation of Annex VIII in Great Britain are just two that immediately spring to mind.

I get a frankly obscene amount of notifications of legislative drafts and proposals, consultations, amendments, and numerous other committee documents. Trying to filter out the less relevant ones to identify those that will have the greatest impact on our readers (without missing anything) is a delicate balance and we cannot expect individual businesses to do this on their own. The work of the industry associations to publicise, campaign, lobby and ultimately negotiate on the most impactful legislation is crucial to the chemical industry and I think a certain amount of outrage is warranted at the comments of Mr Lancini.

By the end of the debate I’d been amused, I’d been angry and I’d been surprised by the revelation that plenary was going to vote on another round of amendments. (Is anyone else getting tired of this?) Which left me scrambling for yet another version of the flipping draft text.

You will not be shocked to learn that the amendments poked at the definition of multi-constituent substances, and offered a time-limited exemption to several of the provisions for some essential oils (or ‘substances containing more than one constituent of renewable botanical origin that are not chemically or genetically modified’ as they are referred to in the text). I intend to refer to them as ‘Essential Oils for ease of typing.

My extremely rough summary of the contentious issue is:

  • Substances that contain another constituent (like an impurity, a UVCB, or a multiconstituent) could previously be classified based on data of the overall substance
  • The new amendments state that a hazardous property of a minor constituent cannot be overridden by data on the overall substance if that data shows the absence or reduced severity of the effect.
    • i.e. the minor constituent property must always be classified
  • Essential Oil manufacturers are VERY UPSET. (I cannot stress this enough) Very, very upset.
  • So, an amendment has been added to exempt products if one of the constituents is an unmodified botanical – because plants are ‘Safe’!

And because the legislators are very confident of these changes, there is also an amendment that says: “Within 6 years of publication of the CLP Legislative Act, the EC will complete a report into evaluation and classification of [essential oils]”.

Other than that, we’re basically where we expected to be with the amendments. They removed one of the proposed hazard categories from ‘Child Safe Fastenings’, but doubled down on ‘Tactile Warnings of Danger’.

There is no further movement on font sizes, formatting, fold out labels, digital labels or multi-lingual requirements. These all stay as described in last weeks newsletter.

The only other tweak that caught my eye was a little insertion that states (paraphrasing heavily) ‘if a harmonised classification is successfully challenged and they find that information was omitted from a REACH dossier, they will enforce against the Registrant’. Which, to me seems like a little back door fundraiser.

To wrap up – because the plenary kicked out some of the proposals (like Eye damage products needing a Child Resistant Fastening), the Legislative Act needs to go to a Trilogue Meeting (which is an Intra-Institutional Committee negotiation). This doesn’t happen with all legislation but it is basically a conciliatory session where a small number of people sit around a table and agree the final text. That text cannot be changed, it can only be adopted or rejected. The trilogue is a closed session, so we can’t give you any news on it until the final text shows up to the Council Reading.

As always, you’ll hear from us when we know more!

Many thanks to Ali for an excellent summary.

I hadn’t really picked up on the mixture classification situation until now, and am astonished that the EU are going beyond the longstanding GHS principle of a classification based on test data over-riding a classification based on the percentage of a hazardous health or environmental component. If you want to check yourself, this is in GHS chapter 1.3, paragraph .

This issue probably affects the essential oil industry the most, because these are some of the oldest UVCB products in the world, and therefore the most likely to have test data on health hazards which can currently over-ride a theoretical classification.

Many industrial mixtures are already classified on the basis of the percentage of components for health and environmental hazards, so it won’t affect them. And the effective ban on animal testing of mixtures means that they are unlikely to obtain the data necessary for classification.

However, this alteration brings yet more classification divergence between the EU and GB, and I wouldn’t be surprised if there are more UVCBs and mixtures already on the market which may have to alter their classifications within the EU.

Link to video of debate: https://www.europarl.europa.eu/plenary/en/vod.html?mode=chapter&vodLanguage=EN&internalEPId=1696359604939&providerMeetingId=2f51e2a7-69da-4801-e973-08dbbe783c02# .

Link to verbatim transcript of debate: https://www.europarl.europa.eu/doceo/document/CRE-9-2023-10-03-ITM-020_EN.html

EU microplastics restriction update

Laura Coward of Lubrizol writes: just wanted to highlight that regarding the Microplastics restriction, I believe microbeads are restricted immediately, including in rinse-off personal care applications.

Paragraph 6 (b) of the restriction says it applies from October 2027 for rinse off products unless [they] contain synthetic polymer microparticles for use as an abrasive, i.e. namely to exfoliate, polish or clean (‘microbeads’)’ – i.e. the transition period does not apply to microbeads and these are restricted straight away.

Thanks very much to Laura for the clarification! (The full restriction text is here: https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX:32023R2055). Plastic beads in shower gel only have an extended transition if they contain ‘fragrance bursts’, and not for the exfoliating effect.

Ali is wishing she’d picked a different ridiculous example for last weeks newsletter. Because the following day she noticed that Microplastic Glitter in Nail Varnish (78(6)g) is permitted until 2035! Which is utterly insane because she really can’t see an argument of ‘essential use’ for that!

Keeping an Eye on ECHA and the EU

In case you missed it, ECHA’s webinar from Tuesday on their approach to assessing chemicals in groups is now available here: https://echa.europa.eu/-/towards-faster-regulatory-action-echa-s-approach-to-assessing-chemicals-in-groups . I know that some readers are very concerned that ECHA’s approach is overly simplistic, and I’d be happy to publish your comments and thoughts on this important issue.

Some excellent advice from Aaron McLoughlin on the exact number of votes you need at various points in the EC system: https://www.aaronmcloughlin.com/the-votes-you-need-in-one-simple-table/ (shared in case any of our readers are directly involved in lobbying).

ECHA received more than 5,600 comments on the PFAS restriction, which I think is a record. Clearly a “hot topic” for many people: https://www.linkedin.com/posts/european-chemicals-agency_echa-receives-more-than-5-600-comments-on-ugcPost-7112374490130440192-rd_u

Chemical snippets

Statistics corner (or lies, damned lies, and….)

Hans Peter Arp of the Norwegian Geotechnical Institute and the Norwegian University of Science and Technology asked a question “Is updating EU chemical regulation like #REACH harmful financially for the European chemical industry?”

He was unsure of the answer, because he’d come across two sets of data showing very different trends: information from VCI (the German equivalent of the Chemical Industries Association) showed a decline in production within Germany itself, whereas Eurostat showed a massive increase in chemical sales. See https://www.linkedin.com/posts/hans-peter-arp-3a934815a_reach-reach-reach-activity-7111937365392134145-JMAd

Unfortunately, this is a classic “apples and oranges” situation (as we were repeatedly told to avoid in school algebra) where the two datasets are not comparable:

  • The VCI data is based on German production data direct from industry, which may not be representative of the EU as a whole, as covered by Eurostat
  • The Eurostat data includes import, export, and manufacture and consumption of chemicals internally in the EU (VCI excludes import)
  • The Eurostat data also does not distinguish between chemicals manufactured by reaction, and those made by formulation

Hans Peter has said he will investigate the Eurostat data further, so it will be good if he can find out anything more, and I will report back if he does. In the meantime, I suspect the VCI data showing of a decline in the production of chemicals within Germany is much more representative of the impact of regulation on EU industry than the Eurostat figures suggest.

Process safety corner

Recent(ish) incidents:

The EU have started an” eNatech” database for Natural incidents affecting technology sites, see an overview at: https://www.linkedin.com/posts/simone-bottinelli-7077b9ab_enatech-ugcPost-7111981449246879745-v7dR . The database itself is at https://enatech.jrc.ec.europa.eu/ .

The OECD also have guidance on preparing for chemical incidents here: https://www.oecd.org/chemicalsafety/oecd-guiding-principles-for-chemical-accident-prevention-preparedness-and-response-third-edition-162756bf-en.htm (although if you are sceptical about the likelihood of “catastrophic climate change”, be warned that this has been updated to include scenarios involving this. However, regardless of which side of the climate debate you sit on, they are likely to be useful in preparing for adverse weather events, the only real difference being the probability of the event happening which you or your consultants choose to use in your predictive modelling).

In fact there is a range of guidance from OECD (rather similar to COMAH/Seveso guidance here in the UK and EU) here: https://www.oecd-ilibrary.org/environment/series-on-chemical-accidents_23114614

Jobs update (UK stats from LinkedIn)

Regulatory Affairs, 3.490 jobs; and Health and Safety, 57,022 jobs.

Thornton and Ross have a couple of interesting roles:

If you’re searching for suitable jobs on LinkedIn, don’t forget you can set your own geographical area, e.g. Liverpool or Leeds.

Infographic of the week

As we’re dealing with the CLP debate and vote in European Parliament this week, I thought you might like this infographic on how the Ordinary Legislative Procedure works there:


The Weekend Watch

A nice soothing watch this week, as we’ve got enough to worry about elsewhere. Especially good if you like mechanical engineering and a certain Danish set of plastic building blocks, you’ll love this video of a 20 different engineering mechanisms made using Lego: https://www.linkedin.com/feed/update/urn:li:activity:7105127493900103680/

The Weekend Recipe

Confession time: I had a bit of a disaster with some shortbread last Saturday, which I was making into a single round biscuit. For some reason, I left in the cooling oven for a couple of hours. It was a golden brown colour throughout (like a Biscoff biscuit), and tasted perfectly fine, but my goodness it was hard! You could have used it as a hammer. So in order to avoid breaking any teeth, I decided to turn it into a biscuit cake, using a recipe I got from my Great Aunty Mary when I was around 10.

Biscuit or digestive cake

  • 1/2 lb (225 g) digestive or overcooked shortbread crumbs (put them in a plastic bag and bash with a rolling pin)
  • 1/4 lb (113 g) butter or margarine
  • 1 tablespoon golden syrup
  • 2 tablespoons granulated sugar
  • chocolate for topping – I used a 100g (3 1/2 oz) bar of Lindt 70% cocoa chocolate

Method: heat the butter, syrup and sugar in a pan over a low heat, and stir until the sugar is dissolved. Add the crumbs, and pack into a greased tin (you can make this thin or into thick bars, depends on the tin size you use – a 7 inch square tin makes a thinner biscuit on these quantities). Chill in the fridge, then melt your chocolate (in the microwave in bursts, or over a low heat) and coat in the chocolate. Mark into squares or rectangles once the chocolate has cooled for a bit. When completely cool, cut up and store in a tin.


  • This worked really well, and because the biscuit crumbs were shortbread, the effect was rather like millionaires shortbread but without the caramel layer (which I might use if I ever overbake shortbread again and redo this recipe!). Perhaps we could call the result “middle-class shortbread”?
  • It was much kinder on the teeth than the original overbaked shortbread, and very buttery, as the shortbread had plenty of butter in its recipe.
  • However, because the crumbs were so dry, they didn’t absorb the butter very well, and I could have used 3 oz butter instead of 4 oz. If you use this recipe with digestive biscuits which aren’t overbaked, they may absorb the butter a bit better (try saying that in a hurry!).

To make this recipe “free from”: to veganise this recipe, use vegan biscuits and margarine, and a suitable vegan chocolate. To make it gluten free, simply use gluten free digestive biscuits.

Reasons to be Cheerful

Ali has suggested a cheerful little song about the amount of radioactivity in bananas:


The Banana equivalent dose (BED) is a real concept, and there are a number of scientific papers relating to it.

And finally, a reminder of Les Dennis (who left Strictly Come Dancing last weekend) in his early years with his late comedy partner Dustin Gee, who died tragically young. If you’re not old enough to remember Coronation Street in its heyday, this might not mean much to you, but it’s quite poignant for those of us of a certain age:


Congratulations to our friends at Airedale Chemicals who have donated defibrillators to their community – they’ve already been used 20 times: https://www.linkedin.com/posts/airedale-chemical-co-ltd_defibrillator-activity-7113432365221179392-tm6S

Many thanks for reading this newsletter, and many thanks to everyone who has contributed to it this week. As usual, if you have anything you’d like to share, please email me and I’ll do my best to include it in the next newsletter.

I hope you have a good day today, and a lovely weekend with your family and friends. Take care, stay safe and I hope to be able to write to you next week.

Kind regards,


Janet Greenwood

TT Environmental Ltd

P.S. Found this Chemicals Coffee Time newsletter useful? why not sign up for the weekly newsletter (and get access to the full email newsletter archive): https://www.ghsclassificationcourses.com/home/newsletter-sign-up/

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