Regulatory Newsletter – March 2023

New CLP classifications for endocrine disruptors and other harmful chemicals now published

The European Commission has published a revision to classification, labelling and packaging of substances and mixtures (CLP) Regulation, introducing new hazard classes for endocrine disruptors and other harmful chemicals.

A breakdown of these new classifications along with the dates to comply with can be found here.

You will need expert support to understand if these classifications apply to you and?have robust case for your classifications. Where these classifications apply, you will need to update your SDSs, Labels, REACH dossiers, and?poison centre?notifications.?

Identifying which substances in your supply chain will be impacted by these changes is likely to be a challenge for many organisations. Our?horizon scanning tool?can help to relieve the burden of this changing situation. It performs a substance inventory check and identifies whether your substances appear on any global regulatory lists. It provides the results in a clear, easy-to-read report, so that you can quickly determine the most recent status of your substances.

Understanding PFAS

Our environmental chemistry and toxicology experts have recorded a short video describing why PFAS are such a ‘hot topic’, the evolving regulatory landscape around them and actions you will need to consider if you manufacture, supply or use PFAS in the EU.?Watch the video here.??

Some PFAS are already restricted under REACH and with the introduction of the universal restriction proposal,?we expect that producers and users of PFAS will need to reformulate products and modify processes in response to tighter regulation and customer demand for safer, more sustainable chemistries.

If you manufacture, supply or use PFAS or are unsure if you?have any in your portfolio, our immediate suggestions would be to:

• Use our horizon scanning tool to identify if you have any PFAS in your portfolio.
• Participate in consultation regarding the universal restriction proposal which began on 23 March.

If you have any questions regarding use or manufacturing of PFAS and need support with identifying and transitioning away from PFAS use, please contact us urgently.

Meet our expert – Simon Cook, Regulatory Consultant

Simon works across a wide range of our regulatory portfolio including SDS authoring, poison centre notifications, global regulations, Emergency Action Code Dangerous Goods List and the Hazmat Conference.?Our customers find Simon a joy to work with and really appreciate his range of regulatory knowledge.

Simon coordinates NCEC's Dangerous Goods Safety Advisor Service (DGSA) and manages the Chemedox? SDS management software as well as being involved in developing new services.

Simon holds an MEng in Chemical Engineering and is currently in training to become a Dangerous Goods Safety Advisor.

Say hello to Simon

New recommendations from ECHA to improve REACH registration dossiers

To help organisations comply with REACH requirements ECHA have updated their recommendations, which include new recommendations to limit animal testing and provide specific guidance on use of read-across.?Read more on what these recommendations mean for businesses here.

From 2009 until the end of 2022, ECHA ran compliance checks on more than 15% of registered substances. By?2027, ECHA will have screened all registration dossiers submitted by the 2018 deadline.?Remember, if ECHA finds a compliance failure, it could lead to problems with the REACH registration and subsequent market access.

With experience in assessing complex and difficult-to-test chemicals, our Environmental Chemistry and Toxicology team provide our customers with technical expertise and guidance on the testing and assessment of substances with challenging properties. We will review your dossier to identify and fill data gaps, strengthen justifications for adaptations, and confirm that all appropriate information has been gathered, to reduce the likelihood of ECHA requesting further information. You can find all our services?here.

Poison Centre – industrial deadline and harmonised submissions????????????????

Deadlines for customer and professional use products have passed, and the remaining poison centre notification deadlines are as follows:

• 1 January 2024 – for industrial use products
• 1 January 2025 – for notifications which were completed via individual Member States and now need to be replaced by the harmonised portal notifications.

We offer a full poison centre notification service for companies who have an obligation to notify their hazardous mixtures and biocides. You can find more on our poison centre services?here.

We will be at SETAC Europe

We are delighted to be presenting and exhibiting at SETAC Europe again this year.

After the phenomenal success and learning opportunities at last year's event, our team is really excited to return. This time we will be presenting 5?posters and will be?participating in 1 session and 1 seminar. Find out more on our attendance at SETAC.

One of our most notable poster and seminar will be on the Persistence Assessment Tool (PAT). The?PAT is a software tool that our environmental chemistry and toxicology experts have developed in conjunction with Concawe and the International Collaboration on Cosmetics Safety.

The tool provides?clear guidance and structure to evaluate data quality, and a quantitative weight-of-evidence methodology to increase consistency, transparency and robustness of persistence assessments.

The PAT will be released soon, but if you want to know more about it in advance, please simply?contact us at [email protected].

If you're also attending SETAC, please do come and say hello to us at Booth 59.

To speak to a member of our team about how we can assist you?with regulatory compliance,?emergency response or sustainability, please?email us at [email protected]?or visit our?website.