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Chemicals Coffee Time Monthly, August 2023

Dear Friend,

After a wet cool summer which seemed to be morphing into autumn, I hope you are enjoying these few days of warm weather.

August is traditionally a month when very little happens in Europe due to the extended summer break in many countries, yet it seems that the flood of information and new regulations continues apace.

International news

GHS Revision 10

Breda Kosi emailed us to say that GHS Rev 10 has just been published, see https://unece.org/transport/standards/transport/dangerous-goods/ghs-rev10-2023 .

No sign of the unsecured pdf version being published yet, although the print version (paid-for) and the secured pdf (free) are both available. Unfortunately the free pdf does not allow you to copy and paste text from it.

Prop 65

Hearing from the HSE/ UK

There were a few surprises here in the UK.

UKCA/ EU CE mark

Firstly, it was announced that the EU’s CE mark will be accepted indefinitely for most (but not all) products. https://www.gov.uk/government/news/uk-government-announces-extension-of-ce-mark-recognition-for-businesses Most of the items relevant to the chemical industry, that is chemical products, PPE etc are covered by this announcement.

However, Sinéad Oryszczuk of CMS pointed out that RoHS items and medical devices may still require the UKCA mark see https://www.linkedin.com/posts/sin%C3%A9ad-oryszczuk-613b2a58_recent-ukca-announcement-not-all-that-it-activity-7097974621987065856-Lmy-/.

Sinead also writes: “I think it’s worth clarifying on the medical devices though, effectively the MHRA has said that the announcement doesn’t apply to them and their approach, but it had already introduced extensions for CE recognition to 30 June 2028 for certain types and 20 June 2030 for others. So the implication is that CE won’t be recognised and UKCA will still be required after these dates for medical devices, but of course this could all change.

Another set of products which seem have been left in a bit of a limbo are those which fall under eco-design rules, this includes a very wide range of equipment such as computers, set top boxes, washing machines, electric motors…. These fall under yet another ministerial department (the Department for Energy Security and Net Zero) and as yet we haven’t heard anything from them.”

Many thanks to Sinead for the update. In practical terms, this is a very good thing for industry because there will not be a need for dual accreditation where your product needs to undergo a conformity assessment.

Unfortunately its a big loss for the test houses in both GB and NI, and we hope that someone is working on a Mutual Recognition Agreement for the Notified Bodies.

GB-CLP Mandatory Classification update

Secondly, there was another GB submission to the WTO for some new and updated GB-CLP Mandatory Classifications.

Many thanks to Nicola Kaye of REACHLaw – Your Partner In Chemical Regulatory Compliance and Sustainability who broke the news on 24th August:

Fyi the GB MCL update has been submitted to WTO indicating publication in Q1 2024 and mandatory implementation in Q3 2025“.  The notification announcement is here, and the list of changes is here: https://members.wto.org/crnattachments/2023/TBT/GBR/23_11998_00_e.pdf

We’ve not had time to analyse the changes, so it will be interesting to see if these updates create any more divergence from EU-CLP. (The first WTO submission made earlier this year mainly involved GB adopting EU Harmonised Classifications into the GB Mandatory Classification list, but there were some significant alterations).

Biocide/ product type removals in GB

The HSE sent out a notification of 19 biocide/product type combinations being withdrawn from the UK, see https://content.govdelivery.com/accounts/UKHSE/bulletins/36b4317.

Here at TT Environmental we have been worried for a long time, even prior to Brexit, about the BPR reducing the number of biocides and biocidal formulations to a point where either certain products can no longer be preserved, or there are so few biocides available that resistance becomes highly likely or inevitable. Clearly, having a UK-only BPR regime is likely to reduce the number of supported biocidal actives and product type combinations still further, making resistance even more likely to develop.

Greenpeace not welcome at DEFRA

In an unprecedented move, Therese Coffey announced in early August that DEFRA are to cease engagement immediately with Greenpeace, a move which appears to have been triggered by their activists draping the Prime Minister’s home in black while he was away on holiday.

Thérèse Coffey has told officials at the Department for Environment, Food and Rural Affairs to cancel any planned meetings with the charity and cease future engagement.

A source at the department said: “Greenpeace have shown they are not a serious organisation and we are not going to treat them that way.

“This Prime Minister has done more for the environment than all of those activists put together.”


UK-REACH possible changes

Thanks again to Neil for inviting such interesting and important guests.

Keeping an Eye on ECHA and the EC

More Harmonised Classification proposals

Consultation ends 29/9/2023

  • 4,4′-methylenediphenol; bisphenol F; CAS 620-92-8
  • bronopol; 2-bromo-2-nitropropane-1,3-diol; CAS 52-51-7

Consultations end 13/10/2023

  • 3,4-dimethyl-1H-pyrazol-1-ium dihydrogen phosphate; CAS 202842-98-6
  • 3,4-dimethyl-1H-pyrazole; CAS 2820-37-3
  • 3,5-dimethylpyrazole; CAS 67-51-6
  • Three boron minerals, ulexite, colemanite (including boron calcium oxide) and tincalconite
  • rape oil; rape seed oil; CAS 8002-13-9

As usual, anyone in the UK who is interested in these Harmonised Classification proposals should comment to ECHA, as this is open to all interested parties, and the HSE recommend you do that before they are brought into EU law and have to be considered in UK law under GB-CLP.

PFHXS EU ban under POPs

Phil Rowley writes – Yet another EU development! The EU have banned PFHXS under the POPs regulation: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ%3AJOL_2023_198_R_0004.

New SVHC proposals.

PFAS restriction

Am I missing something, but if we’ve got a Restriction on PFAS coming in, why do we need the whole architecture of the new PMT/vPvM hazards as well? I

IUCLID-6 changes

Alternatives to Authorised Chemicals in the EC

Alison Potts notes that some of these alternatives are themselves on the SVHC list, so you need to be very careful that you’re not substituting an Authorised chemical with one which may become Authorised in a few months or years time.

ECHA take on battery safety

ECHA have announced they are “going to make batteries safer”. I’m not sure whether they’re referring to traditional or lithium batteries, but how does that tie in with the push for electricity, particularly electric vehicles? See https://echa.europa.eu/-/new-task-for-echa-to-make-batteries-safer

We can only hope that this new duty does not interfere with their core responsibilities under REACH and CLP.

Infographic of the month

The Weekend Read

The Weekend Recipe

Here is Ali’s Famous Pavlova. It makes a regular appearance at family functions and holidays because it’s gluten free and pretty easy to throw together. The meringue can be baked the night before and if you have a willing ‘helper’ in the kitchen then decorating it can be safely assigned to child.

  • 3 egg whites
  • a pinch of salt
  • 250g (9oz) castor sugar
  • 1 tsp vanilla extract
  • 1 tsp vinegar
  • 300ml fresh double cream
  • fruit to decorate

Draw round your intended serving plate onto greaseproof paper/baking parchment

Whisk the egg whites with the salt until very stiff. Gradually whisk in the sugar until it forms firm peaks again. Fold in the vanilla and vinegar with a metal spoon.

Spread the meringue mix onto the baking paper. Keep within the circle (so it’ll fit on the plate!). Flatten slightly to make it easier to decorate.

Bake for 1 hour at 140 DegC. Then turn off the oven and let it cool in the oven (it’ll crack less than leaving it out on the side).

Once cool, whip the cream until stiff and pile onto the meringue. Decorate with the fruit.

Notes – If gluten free then make sure you are using spirit or wine vinegar. If you are lacto-free then the Arla lacto free cream works great (most people can’t tell the difference) but you will want to whisk a tablespoon of icing sugar into the cream to make sure it holds firm! Oat and soya creams don’t whisk well so always check the label.

You can make it extra fancy with dark chocolate shards, or a berry coulis mixed through the cream.

Ali says that it’s nearly impossible to go wrong with this pavlova recipe, unless you manage to set fire to it. She can neither confirm not deny that this impressive act has taken place!

Reasons to be Cheerful

We have been continuing our Mitchell and Webb theme lately:

Many thanks for reading this LinkedIn newsletter, and many thanks to everyone who has contributed. 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 newsletter.

It would be great if you’d like to subscribe to this newsletter, or even our weekly email one https://www.ghsclassificationcourses.com/home/news (which includes access to the email archive).

Look forward to chatting to you in late August or early September

Kind regards,


Janet Greenwood, TT Environmental Ltd

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