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Chemicals Coffee Time Monthly, December 2023

Dear Friend,

Happy New Year! I hope this newsletter finds you safe and well, and that you had an excellent Christmas. December 2023 was spectacularly busy for EU legislation, including some announcements after our last weekly email newsletter of the year, so I’ll dive straight in.

EU news in December

EU-CLP legislative act update

The huge news in December was that the Trilogue process on the CLP legislative act changes finished, with some changes agreed. A draft document showing the results of the trilogue discussions was published just before Christmas. This still needs to be approved by a vote in the EU Parliament, but no further changes are supposed to happen, although, as usual, I have to warn you to not take any firm actions until the actual legislation is published, just in case there is a change in the meantime (it has happened before!).

The text is available to download and read here:

We’ll be evaluating it in full in the New Year, but Alison Potts has pulled out some “highlights” that we know you’re all eager to hear.

Firstly the labels:

  • Fold out labels are to be permitted in all cases (not just for small or awkwardly shaped packs)
  • Font Sizes (the reason you’re all here!) are specified in height (millimetres). Packages less than 0.5L, minimum font 1.2mm. Packs greater than 0.5L up to 3L, minimum font 1.4mm. Packs greater than 3L up to 50L, minimum font 1.8mm. Packs greater than 50L, minimum font 2.0mm.
  • Compromise – For inner packaging where contents are <10ml you can have smaller fonts
  • Bad news – Label formatting is back. Text must be printed in black on a white background. The distance between text lines must be => 120% of the font size. You must use a single font (without serifs)Letter spacing must be ‘appropriate’
  • The formatting requirements and layout for fold out labels move from the guidance document to the legislation

Secondly, child resistant fastenings and tactile warnings:

  • Good news – there will be no immediate changes to either of these measures
  • The commission is obliged to carry out a review within 5 years of the effectiveness of the current provisions to justify extending the measures
  • However, if justified they can then bring in new measures via delegated act (without vote)

And finally, the C&L Inventory

  • The published C&L inventory will no longer be anonymous
  • Notifiers will be obliged to update their notification within 6 months of an update to the REACH dossier classification
  • Divergent classifications (from the REACH registered, or for non-REACH substances the most severe classification) must be justified with the agency
  • Unjustified, or un-updated C&L notifications will be deleted

The act is expected to go to vote soon, and of course we will be covering the full measures and timelines in more detail once it’s published officially.

Reminder: these requirements will apply to the EU, and to Northern Ireland under the terms of the Windsor Framework, but they will not apply to Great Britain (unless they are adopted separately, but there is no sign of this at the moment).

EU-CLP Harmonised Classifications update

The 18th ATP to CLP was brought into effect on 1st December 2023, and you can find the consolidated version of the 18th ATP itself here: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:02022R0692-20220503 ); and a consolidated version of EU-CLP, including the 18th ATP updates here: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02008R1272-20231201.

The good news is that the HSE have already updated the Mandatory Classification List with the classifications which GB is adopting from 17th and 18th ATP to CLP, although as I’m sure you’re aware, not all of them have been adopted, and some have been altered within GB. More details here: https://www.linkedin.com/pulse/chemicals-coffee-time-monthly-october-2023-janet-greenwood-tgyde/

Proposed and ongoing EU regulations affecting the chemical industry

Chemical Assessment reform is still on the agenda: Darren Abrahams of Steptoe & Johnson PLLC writes: A surprise for those who thought this might fall by the wayside in the transition to a new Commission and European Parliament. The CSS is very much alive and kicking. https://www.linkedin.com/posts/lukaszgorywoda_one-substance-one-assessment-chemicals-activity-7138535293103591424-mVBJ.

One of the suggestions is a common data-sharing platform, which Aaron McLoughlin of Fleishman Hillard has kindly posted: https://environment.ec.europa.eu/publications/proposal-regulation-establishing-common-data-platform-chemicals_en .

Internet sales of chemicals. ECHA have just completed training EU member states enforcement agents in the rules for internet sales of chemicals, so we may find that there is a clamp down in this area in the next year or so. This news came out of a meeting where the ECHA director, Sharon McGuinness, gave a presentation to the EU parliamentary Environment Committee recently. We have had some difficulty finding the video of this meeting, but ECHA’s take on it can be found here: https://echa.europa.eu/-/dr-sharon-mcguinness-echa-is-now-truly-a-chemicals-agency-not-only-the-reach-one-1

EU Ecodesign update. Ecodesign has now been expanded to include “detergents, paints, lubricants and chemicals“, a bit of a shock for those of us oldies who think it is only supposed to be about articles! Full details here: https://www.europarl.europa.eu/news/en/press-room/20231204IPR15634/deal-on-new-eu-rules-to-make-sustainable-products-the-norm.

The EU General Product Safety Regulation will be updated in 2024. A reminder that these rules also apply to chemical products as well: https://eur-lex.europa.eu/eli/reg/2023/988

Sharing chemical legislation tasks between EU agencies. Steven Brennan of TSG spotted that there is a proposal to share chemical legislation tasks differently between EU agencies. https://www.linkedin.com/posts/steven-brennan-reach_proposal-for-a-regulation-on-the-re-attribution-activity-7138818048458657792-yKuh .

EU-REACH test method regulations update. Steven has also highlighted that there is a proposal to update the REACH Test Methods Regulation, to include https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13966-Chemicals-regulation-update-of-EU-rules-for-test-methods_en . It’s open for comments until the 9th January 2024, not a lot of time when you consider the Christmas holidays, so get your views in ASAP. These include bringing in new OECD methods, including some non-animal tests.

The N,N-dimethylformamide EU Restriction entered into force on Wednesday 13th December, many thanks to Phil Rowley for the reminder https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.L_.2021.415.01.0016.01.ENG&toc=OJ%3AL%3A2021%3A415%3ATOC

Identification and naming of substances – EU-REACH and EU-CLP Phil also spotted that there is new ECHA Guidance for Identification and naming of substances under REACH and CLP. Essential reading for those working with novel substances, or putting together SIPs.

Chrome VI Substances Restriction proposal. ECHA have launched a consultation for the EU’s proposed Chrome VI Substances Restriction: https://echa.europa.eu/calls-for-comments-and-evidence/-/substance-rev/75309/term . The proposed Restriction would remove the Chrome VI Substances from the Authorisation List and instead have permitted uses under the Restriction.

Proposed Harmonised C&L for Grouped Strontium Compounds. The proposal would add Repr. 1B (H360D) to a number of grouped substances, so if you’re using any Strontium compounds it’s certainly worth taking a look to see if you’ll be affected. You can find the proposal here.

OEL consultations. There are two ongoing consultations for EU level Occupational Exposure Limits. These are for Boron and boron compounds (consultation closes Jan 12th) and Bisphenol A (consultation closes Feb 19th). Details here: https://echa.europa.eu/oels-pc-on-oel-recommendation

The draft 2024 – 2026 CoRAP list was published https://echa.europa.eu/documents/10162/879660/corap_update_2024-2026_en.pdf/b0e44cd2-7abe-a148-97c6-a2042ded32bb. The current CoRAP list is here (if you want to see what the future holds for your chemical inventory): https://echa.europa.eu/information-on-chemicals/evaluation/community-rolling-action-plan/corap-table .

Turkey News

The much-anticipated extensions to the Turkey REACH (KKDIK) registration deadlines have been officially published, see:

GB News

Gas-powered FLT safety in the UK

If you have gas-powered Forklift Trucks, FLTs, there may be an issue with gas quality, which can affect the FLTs performance, see https://www.linkedin.com/posts/colin-burton-8ba8685b_forklift-propanepoor-quality-supply-uk-activity-7138473140086591489-A4MG . I’m not sure if this issue is unique to GB, or whether it is affecting other countries too.

A plea to DEFRA and the HSE on UK-REACH registration information

Something which we at TT Environmental have come across recently is a glitch in the published information available to potential UK-REACH registrants.

It’s really important to potential registrants to see if other companies are going to register, due to the cost of REACH registration.

In theory, you would be told if there is at least one other Registrant when you make a UK Section 26 Inquiry – but to do that, you need to pay for the substance identity data, and make up an Inquiry Dossier (or get someone to do that for you), which will involve at least £2,000 – £3,000 for the identity costs (unless you happen to have the data already, e.g. for EU-REACH registration).

And when you’re trying to make a commercial decision about whether to register or not, you don’t really want to shell out for Substance Identity Profile (SIP) tests unless you’re going ahead.

It would be very helpful if the HSE could either update the list of Grandfathered substances, or produce a second list of non-Grandfathered registered substances, so that industry selling in the UK has full disclosure without any cost.

Interestingly, a close reading of the UK-REACH regulation shows that all of the requirements to publish REACH registration information which were applicable to EU-REACH have been removed, and as far as I can tell, there is no publication duty on the UK Agency, that is HSE, at the moment. But it is something which is potentially acting as a barrier to trade in GB compared to the EU, and it would be a very useful list to have access to.

Our Chemicals Coffee Time Heroes of 2023

We’d like to take a moment to acknowledge some of the people who have worked exceptionally hard to support the UK chemicals industry this year.

First among them being Douglas Leech of Chemical Business Association who invested immense time and energy to lobby successfully behind the scenes to get Annex VIII to CLP removed in the UK.

Ian Stone and his team ran ChemUK 2023 very successfully in May, and we are looking forward immensely to ChemUK 2024, where the Chemical Regulations Self Help Group will have a stand in the Regulatory section.

The Regulatory Helpdesk team at the Health and Safety Executive continued their sterling efforts to educate the GB chemical industry on UK-REACH and GB-CLP, including manning the helpdesk by phone and email.

And although we in industry may wish for a close relationship with EU-REACH and EU-CLP along the lines of the Swiss adoption of most of the same regulations and classifications, we have to acknowledge the CLP team at the HSE, who have produced an enormous number of technical reports on potential Mandatory Classifications in the past couple of years.

Thank you to everyone for your efforts on behalf of the chemical industry.

Infographic of the month

A simple but inspiring infographic about success: Success comes in cans.pdf .

The weekend read

As we went through Advent, I thought our readers might like a very uplifting video about Tammy Peterson’s healing from cancer. She firmly believes that it was helped by her prayer practice, although as her husband points out, they had the best surgeons as well.

But given how strong the effect of the brain and our thoughts can be on our physiology, prayer, especially the meditative state of the Rosary is likely to help.



I was particularly struck in that video with a comment made by her husband, Jordan Peterson, which is that her prayer was not about praying to live, but “to conduct oneself appropriately given the situation at hand, which is the true meaning of putting oneself in the hands of God“.

He also mentioned a “child like state“, and this reminded me of Chris Hughes of Ricardo’s description of a scientist recently “Humility, honesty, generosity, and a willingness to question one’s own presuppositions and beliefs. All hallmarks of good scientists...” (Chris’s comment is under this LinkedIn post:https://www.linkedin.com/posts/michael-manefield-666662142_correspondence-on-defluorination-of-perfluorooctanoic-activity-7128890212272795648-n6WD)

The link between faith and science may not be as wide as is commonly believed.

The weekend recipe

I am not a believer in starting a diet at the coldest, darkest time of the year, instead thinking diets should be during Lent (that is, if you’re not changing your eating patterns entirely, which tend to be the most successful way to do things). So here’s a Chocolate Fudge Cake as requested by my younger nephew for his 30th birthday. It’s based on a BBC Good Food recipe, but also translated into Imperial measurements and with a slight tweak on one of the ingredients.

Chocolate Fudge Cake

Cake Ingredients

Icing ingredients

  • 100g (3.5 oz) unsalted butter
  • 225g (8 oz) icing sugar
  • 40g (1.4 oz) cocoa powder
  • 2½ tbsp milk (a little more if needed)


Heat your oven to Gas Mark 4, and take 18cm (7 inch) sandwich tins, line the base with paper, then grease with a little spare sunflower oil. Sieve the flour, cocoa powder and baking soda into a large bowl, then add the caster sugar and stir to mix using a balloon whisk. Make a well in the centre, and add all the wet ingredients – golden syrup, beaten eggs, milk and oil, and stir until well combined and smooth. The BBC recommend using an electric whisk, which will help aerate the mixture.

Pour equal amounts into each tin, and bake in the centre of your oven (which must be up to temperature before putting the cakes in), for 25 – 30 minutes until risen and “firm to touch”. Cool in the tine on a wire rack for 10 minutes, then turn out onto the rack to continue cooling. Keep away from dogs, small children and other potential thieves – but especially from dogs, because you don’t want to given them theobromine (chocolate) poisoning (briefly they appear to metabolise the theobromine into caffeine, which they can’t handle very well).

While the cake cools, you can make the icing by beating the butter in a bowl until it’s soft. Sieve the icing sugar and cocoa powder together into the butter and beat in gradually. Add enough of the milk to make the icing “fluffy and spreadable”.

Once the cakes are cool, sandwich them together with the icing and top with a layer of icing as well.


  • I used full fat milk as we only have semi-skimmed in the house for guests. When it came to combining the wet ingredients into the dry ingredients, I didn’t bother beating with my electric beaters, just a wooden spoon. I’m not sure if it made a difference, but the sponges rose into mounds – maybe semi-skimmed would have risen more evenly? (due to the oil, it is quite a liquid raw batter, and is level when you put it in the oven).
  • Putting in 2 flat tablespoons of cocoa gave quite a mild chocolate flavour, but the icing gives a much deeper chocolate note. Speaking of icing, as our kitchen is generally cold, I made the icing quite stiff so that in my nephew’s modern well-insulated flat it would be about the right texture.
  • This did take about 5 minutes longer to bake than a butter-based sponge, and had quite a different flavour compared to a chocolate sponge made with butter, a bit “milder”. Luckily, using butter in the icing helped mask the flavour of the sponge. (What do you mean, why did you pinch a bit? I had to slice off the tops to ice the cake, and there was leftover icing – cook’s perks :)!)
  • The sponge texture was nice and soft, although not really “fudgy” in the way that a brownie is.

Free from notes: In theory, you could use a plant milk instead to make the cake lactose free, and use a lactose free alternative instead of butter for the icing (Arla’s Lactose Free spreadable butter is good, and probably won’t need much extra plant milk, as it’s quite soft). However, you might need to add some lemon juice to react with the baking soda and produce more bubbles. To veganise, use plant milk and margarine instead of lactose free butter.

Reasons to be Cheerful

Our Reasons to be Cheerful funny videos included:

  • Dead Ringers – Drink Shopping: 

    it’s even worse for internet shopping, of course :)!

  • Dead ringers: Nigella does her tax return: 
  • Horrible Histories: Christmas songs compilation: 

We also included some less well-known Christmas music, including:

  • The Angel Gabriel from Heaven Came (a Basque carol): 
  • a very beautiful anthem, A Spotless Rose, by Howells: 
  • a charming carol, Up Good Christian Folk and listen: 
  • and I couldn’t resist a very good version of Once In Royal David’s City from Kings College Cambridge: 

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 January or early February.

Kind regards,


Janet Greenwood, TT Environmental Ltd

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