May 2025 Edition

ChemRegs Newsletter – May 2025

New EU C&L Inventory now in ECHA CHEM

The redesigned EU Classification and Labelling (C&L) Inventory is now available in ECHA’s new chemicals database, ECHA CHEM. The C&L Inventory comprises information on over 4 400 EU-level harmonised classifications, and seven million classifications submitted by companies via EU CLP notifications and EU REACH registrations. In total, the inventory includes data on approximately 350 000 substances.

The integration of classification and labelling information into ECHA CHEM follows the initial launch of the database in January 2024, which featured information on over 100 000 REACH registrations submitted by companies. The new inventory is designed to help users easily locate the classification with the highest agreement and also incorporates recent regulatory developments, such as the new EU CLP hazard classes.

The new hazard classes are:

  • ED HH in Category 1 and Category 2 (Endocrine disruption for human health)
  • ED ENV in Category 1 and Category 2 (Endocrine disruption for the environment)
  • PBT (persistent, bioaccumulative, toxic), vPvB (very persistent, very bioaccumulative)
  • PMT (persistent, mobile, toxic), vPvM (very persistent, very mobile)

The new database is refreshed regularly with new and updated notifications.

For the time being, the old C&L Inventory is updated daily. However, it will not include information on the new hazard classes.

The EU C&L Inventory is valid for the EU, while the GB MCL (Mandatory Classification List) is specific to Great Britain. The GB MCL list is a subset of the EU CLP’s harmonised classifications and was established when the UK left the EU, it is updated annually to keep the entries up to date with scientific and technical developments.

Publication of GB mandatory classification and labelling (GB MCL) Agency Opinions

The next batch of 10 new GB MCL Agency Opinions is now available for download in the GB MCL publication table.

These GB MCL Agency Opinions relate to substances for which HSE (as the GB CLP Agency) published an Agency Technical Report under Article 37 of the GB CLP Regulation in 2024.

A GB MCL Agency Opinion formally proposes the GB mandatory classification and labelling for chemical substances, based on the scientific and technical assessment of the scientific data in line with the GB CLP Regulation, together with an assessment of the policy and socio-economic impacts on the UK.

It sets out whether there is adequate scientific evidence to support a new or revised GB MCL of a substance and what the potential impact of the proposed GB MCL may be.

This includes a new Agency Opinion on the classification and labelling of copper substances. The copper substances concerned are:

  • Copper (I) oxide; copper (II) hydroxide; copper (II) carbonate – copper (II) hydroxide (1:1); copper flakes (coated with aliphatic acid), which are active substances in biocidal products under the GB BP Regulation
  • Bordeaux mixture, reaction products of copper sulphate with calcium dihydroxide, which is an active substance, approved for use in plant protection products under the GB PPP Regulation.

Copper substances are also industrial chemicals that fall within the scope of the UK REACH Regulation but only copper (I) oxide, and copper (II) carbonate – copper (II) hydroxide (1:1) have entries in the ‘UK REACH: grandfathered registrations notified substance list’ (July 2021).

Copper substances have existing mandatory classification and labelling entries in the GB MCL list and these entries were open to public consultation and reviewed in an Agency Technical Report in 2024. This is a targeted technical report which only considers the health hazard classification of acute toxicity, as the physical and environmental hazard classes were not assessed and no classification for physical hazard classes or environmental hazard classes are proposed.

The reason for this is that in the 17th ATP to EU CLP (Commission Delegated Regulation (EU) 2021/849), acute toxicity estimates (ATE) were introduced for a number of copper substances. The ATE values are used to determine the classification of mixtures containing substances classified for acute toxicity. These ATE values did not originate in opinions of the Committee for Risk Assessment (RAC), meaning that the HSE (as the GB CLP Agency) was not required to consider them under Article 37 of GB CLP. As such, the HSE prepared a mandatory classification and labelling (GB MCL) report under Article 37A, in order to propose the inclusion of ATE values on the GB MCL list and harmonise them with EU CLP.

At the time of publication, the classification and labelling proposed in these Agency Opinions have not been agreed and/or adopted in GB.

The GB MCL publication table is available here, and the new Opinions are identified in column I of the table with the prefix “New !”.

HSE expect to publish the next batch of Agency Opinions in August 2025.

BAMA DSEAR

BAMA has updated the Guide to the Dangerous Substances Explosives Atmosphere Regulation (DSEAR), which provides advice on managing risks in the aerosol sector.

The BAMA guide to DSEAR concentrates on the areas of specific interest to the aerosol industry. The first edition,
published in 2002, was written by an ad hoc working group of BAMA members to supplement the UK Regulations
and HSE Approved Code of Practice (ACoP L138) and was reviewed by members of the aerosol industry and by HSE.

The updated second edition, again reviewed by members of the aerosol industry, mainly updates regulatory references in light of the UK leaving the European Union in 2020 but the guidance itself is largely unchanged.

The Guide outlines the regulatory framework, emphasising risk assessments, general safety measures, and hazardous area classifications. Employers must identify risks, implement controls, and classify areas into zones based on the likelihood of explosive atmospheres. ​ Key applications include aerosol filling, warehousing, and disposal of reject aerosols, with tailored frameworks for risk assessments. ​

Equipment used in hazardous areas must comply with various regulations detailed in the guide. The guide stresses emergency preparedness, safe practices, and adherence to industry standards for safety and compliance.

To download the free Guide, 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.

IATA Addendum

IATA has issued a 30-page addendum to the current IATA Dangerous Goods Regulations 66th Edition (English), the addendum is effective 30 April 2025 and available for download from here.

The amendments mainly cover lithium and sodium batteries, although there are some important new operator and state variations added.

The addendum also adds two new variations of existing UN numbers to the Dangerous Goods List – UN 3423 Tetramethylammonium hydroxide, solid, and UN 1835 Tetramethylammonium hydroxide, solution. Additionally, updates have been made to UN 3551 Sodium ion batteries, and UN 3552 Sodium ion batteries packed with or contained in equipment.

Special Provision A181 no longer applies to UN 3552 as A181 was originally written for lithium batteries packed with or contained in equipment and not sodium ion batteries.

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

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