Speciality Chemicals Magazine JAN / FEB 2025 | Page 49

REGULATION & COMPLIANCE that poison centre notification is still recommended within GB , it is just a simplified notification process to the UK poison centre located in Birmingham .
However , with the reimplementation of the 14th and 15th ATPs , which were mostly lists detailing mandatory substance classifications , the UK authorities used the opportunity to remove the contentious titanium dioxide and granulated copper classifications . Other Annex VI classifications have been updated in the GB Mandatory Classification List ( MCL ), which now includes classifications up to and including the 19th ATP .
The UK has not always adopted the same classification simply because a substance was classified in an ATP ; in some cases it has deliberately chosen to diverge . To date , it has evaluated 48 of the substances on the 21st and 22nd ATPs , with the aim of implementing them in 2025 , but this is not an exhaustive list of the substances that had their classifications included in these EU documents , leaving some divergence in place .
CLP : The ongoing saga
The EU also released a directive in March 2023 introducing new hazard classes for persistent , bioaccumulative and toxic ( PBT ), very persistent , very bioaccumulative ( vPvB ), persistent , mobile and toxic ( PMT ) very persistent , very mobile ( vPvM ) substances , and both human and environmental endocrine disruptors .
New classifications are usually introduced into local legislation via the UN ’ s Globally Harmonised System , which outlines the criteria and calculation method for each end point . The regions will then introduce these endpoints as and when they feel appropriate . Unusually , in this case the EU has chosen to introduce the new end points locally , before they have been accepted at UN level , with the aim to then fast-track then through the UN process .
This method has caused some concern within the parties that attend the UN meetings , with many regions trying to slam on the breaks , citing not enough evidence to delay the implementation of these new end points . They include the UK , which has stated it has no intention of aligning with the EU on this matter until the new end points have passed UN approval .
Finally , on 20 November 2024 , the EU Council released another new document updating the labelling requirements for chemical products . This regulation aims to improve the clarity around labels for products sold online or as bulk refill stations , and brings in new requirements regarding the layout and sizing of labels . The UK authorities have not made a final decision on whether to implement any or all of these changes . Until they do , suppliers to both markets will need to make sure the product is labelled in accordance with the relevant market .
REACH : Is it allowed ?
Two of the major aspects of REACH are Authorisation and Restriction . This process is designed to reduce the amount of particularly hazardous substances being used in society , and instead have them replaced with suitable alternatives . Substances that are singled out for these processes typically meet at least one of four criteria : carcinogenic , mutagenic and reproductive ( CMR ), PBT , vPvB and endocrine-disrupting .
These processes have created a significant path of divergence between GB and the EU because , whilst the EU has continued to highlight and assess substances for both authorisation and restriction , the GB authorities have so far added no new entries since it left the EU . Whilst many of these are expected to be soft changes as GB will eventually catch up ( it has released a work plan for 2025 that includes some of this work ), there are some entries where a hard change is expected .
For example , the per- and polyfluoroalkyl substances ( PFAS ) restriction in the EU is extensive both in substances involved and product types covered , whilst GB has singled out a smaller selection of substances and is mostly focusing on firefighting foams . The UK authorities
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