July 2025 Edition

ChemRegs Newsletter – July 2025

Defra UK REACH Consultation

Defra want to hear your views on government proposals to extend the UK REACH deadlines for businesses to submit dossiers for transitional registrations and the dates for HSE (the UK REACH agency) to carry out compliance checks on 20% of registration dossiers.

The existing deadlines are October 2026, October 2028 and October 2030. These deadlines are phased according to the tonnages and hazard profiles of the substances being registered.

Under UK REACH, businesses are required to register with the UK REACH Agency (the HSE) information on chemicals substances that are placed on the GB market. When the UK left the EU, information on substances on the GB market which had been registered with UK REACH was not passed to the HSE. The substances in question have remained on the GB market, but this information still needs to be registered with UK REACH.

As the first of these deadlines is fast approaching, government intervention is considered necessary to provide sufficient time to further develop and implement the UK REACH alternative transitional registration model (ATRm) and reduce the likelihood of companies making unnecessary investment in complying with existing deadlines.

This is because the detailed design of the ATRm is still under review, and HSE don’t know exactly what information industry will be required to provide by the current submission deadlines.

It is therefore considered necessary to consult on revised transitional submission deadlines, which provide sufficient time for the government to complete the ATRm and for industry to prepare to comply.

The proposed new deadlines under consultation are:

  • Option 1: October 2029, October 2030, October 2031
  • Option 2: April 2029, April 2031, April 2033
  • Option 3: April 2029, April 2030, April 2031

Option 1 is the government’s preferred option as it allows time to finalise the design and implementation of the ATRm and provides industry with a transition period of approximately two years.

This consultation is also seeking views on the government’s proposal to extend the dates for the requirement on HSE to carry out compliance checks on 20% of registration dossiers received. This applies under Article 41(5) of the UK REACH Regulation. At present this duty aligns with the current submission deadlines.

The consultation opened on 14 July 2025 and will last for 8 weeks, closing on 8 September 2025.

Responses to the consultation can be provided in one of the following ways:

  • Online using the Citizen Space consultation hub at Defra (preferred). A link to this can be found here: Defra – Citizen Space
  • By email to UKREACHextension@defra.gov.uk
  • By post to UK REACH Legislation and Policy team, Defra Ground Floor, Seacole Building, 2 Marsham Street, London, SW1P 4DF

ECHA Updates Guidance on Labelling and Packaging

ECHA is updating their Guidance on labelling and packaging under CLP. This was last revised in March 2021 as Version 4.2 and a draft version 5.0 (XXXX 2025) has been sent to the Partner Expert Group (PEG) for comments.

The guidance is being updates to implement the amendments arising from the recent revisions to CLP given in Regulation (EU) 2023/707 and Regulation (EU) 2024/2865.

This includes:

  • Definitions for “data carrier”, “refill”, and “refill station” (Article 2);
  • Explicit requirement to identify an EU based supplier responsible for fulfilling CLP requirements on the label ((Article 4(11));
  • Addition of new hazard classes in Article 18(3)(b) concerning product identifiers for mixtures;
  • Labelling derogation for ammunition (Article 23 and s Annex I, 1.3.7);
  • Amendment of Article 25 regarding supplemental labelling;
  • Amendment of Article 29, as well as Annex I, 1.5.1.2 and 1.5.2.4.1, and Annex II, Part II, regarding exemptions from labelling and packaging requirements;
  • Amendment of Article 30 on updating label information;
  • Amendment of Article 31 regarding general rules for the application of labels, including legibility;
  • New chapter 3 on labelling formats, including digital labelling (including Annex I, 1.6);
  • Addition of supply via refill stations ( Article 35(2)(a) and Annex II, 3.4);
  • Amendment of Article 48 concerning advertisements;
  • Addition of distance sales offers (Article 48a);
  • Application dates, transition times per provision;
  • Revision of Annex I, Table 1.3 on minimum dimensions on labels, pictograms, and font size;
  • Addition of Annex I, 1.2.1.5 on label characteristics;
  • Addition of Annex I, 1.2.1.6 on fold-out labels;
  • Clarification on terminology, where needed, for example typographical terminology (line-spacing),“legibility” and “readability” in the context of a label and the application of the formatting rules.

However, when the draft Guidance will officially be approved is now affected by the latest EU proposal to postpone several of the CLP updates covered in the new guidance until 2028. (See also our June Newsletter).

The latest EU proposal aims to postpone the dates of application of the mandatory formatting requirements, provisions on advertisements and distance sales, obligations laying down six month deadlines for the label update and rules on the labelling of fuel pumps introduced by Regulation (EU) 2024/2865, in order to provide legal certainty for businesses and to avoid having different application dates for the same type of obligations imposed on businesses by two amending acts to the CLP Regulation.

If adopted, the proposed legislation will lay down a new application date of 1 January 2028 for all the abovementioned provisions.

UNECE Announces the 11th Revised Edition of GHS

The United Nations Economic Commission for Europe (UNECE) has published amendments to the Globally Harmonized System of Classification and Labelling of Chemicals (GHS). This will be released as the 11th Revised Edition of the GHS.

The GHS is sometimes referred to as the ‘Purple Book’ reflecting the purple binding of the published version of GHS. This is similar to the Transport of Dangerous Goods system (UN Model Regs) which is often referred to as the ‘Orange Book’.

The GHS defines physical, health and environmental hazards of chemicals and harmonises classification criteria. It also standardises the content and format of chemical labels and Safety Data Sheets. It is implemented in the EU and UK by both the CLP and REACH Regulations.

The amendments to the 10th revised edition of the GHS were approved by the UN Committee of Experts on the Transport of Dangerous Goods and on the GHS at its twelfth session on 6 December 2024. These will form the basis of the upcoming 11th revised edition of the GHS, including, among others:

  • provisions further clarifying the classification criteria for aerosols and chemicals under pressure (chapter 2.3);
  • new guidance for classification for skin sensitization using non-animal methods (chapter 3.4);
  • classification for substances and mixtures that are hazardous by contributing to global warming (chapter 4.2);
  • further rationalization of precautionary statements to improve users’ comprehensibility while taking into account usability for labelling practitioners; and
  • a new section in annex 11 with guidance addressing identification of simple asphyxiants.

The electronic version of GHS Rev.11 will be published for free download from the UNECE website in September 2025.

BAMA updated Transport Guide for Aerosols – 16th Edition (2025)

The British Aerosol Manufacturers’ Association (BAMA) has updated their guide on the transport of aerosols the ‘Transport Guide for Aerosols – 16th Edition (2025)’.

This guide provides comprehensive and updated information on the safe and legal transport of aerosol products, classified as Class 2 dangerous goods.

The updated edition reflects the latest regulatory framework based on the UN Model Regs (Orange Book), with adaptations for ICAO (air), IMO (sea), ADR/RID (road and rail) and the UK’s Carriage of Dangerous Goods (CDG) regulations, including UK-specific exemptions and commercial practices.

The Guide is free to registered members and to download, go to the BAMA Library on at www.bama.co.uk where there are many more guides, literature and newsletters, including the free BAMA Quick Guide – The UK Aerosol Dispenser Regulations and the GB Market.

For more information on anything in this Newsletter, please contact us at info@chemregs.co.uk

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