Chemical compliance

What’s happening? Here is an update for June 2024:

REACH: EU adopts restriction on siloxanes D4, D5 and D6
UK REACH: New public consultation on ATRm
USA: Chemical Data Reporting deadline approaching
USA: TSCA new and existing chemical programmes

REACH: EU adopts restriction on siloxanes D4, D5 and D6

The European Commission has adopted an EU-wide restriction on siloxanes D4, D5 and D6.

The Regulation enters into force on 6 June 2024 and the restriction will apply from 6 June 2026.

The conditions of the restrictions are outlined here and in the Annex to the Commission regulation.

D4, D5 and D6 are used in various consumer and professional products, including cosmetics, dry cleaning, waxes, and washing and cleaning products.

As reported by the European Chemicals Agency (ECHA), the restriction would potentially reduce up to 90% of emissions of these very persistent and very bioaccumulative substances into the environment.

Find out more about the EU REACH restriction process here.

UK REACH: New public consultation on ATRm

The long-awaited public consultation on the UK REACH alternative transitional registration model (ATRm) was released on 16 May 2024 and is open until 11 July 2024.

The proposal covers four key areas:

• Registration related requirements: hazard requirements, use and exposure information, and Chemical Safety Reports (CSRs)
• ATRm regulatory powers and duties: transitional evaluations, compliance checks and publication of data
• Grouping of substances: data sharing and joint submission of data, and
• Other improvements: including the restrictions process, reporting processes and protections against animal testing

Key takeaway

The proposed transitional model indicates that the hazard requirements for transitional registrations will be reduced without undermining the “no data, no market” principle of REACH.

For example, for 1-10 tonne registrations, the only requirement will be to provide the hazard classification.

This means the cost of a UK REACH transitional registration will be reduced by up to 70% compared to the current baseline.

The consultation also highlights the government’s intention to use the ATRm to:

• focus on Great Britain’s chemical market, and
• respond to previous shortcomings in the information provided in REACH registrations through the requirements to improve the quality of use and exposure data

H2 Compliance encourages companies impacted by UK REACH to respond to the consultation, and will comment and provide further details on its website soon.

Please reach out if you have any questions or require support.

USA: Chemical Data Reporting deadline approaching

The 2024 Chemical Data Reporting (CDR) cycle started on 1 June and runs until 30 September 2024.

CDR concerns manufacturers and importers, and the US Environmental Protection Agency (EPA) has just released guidance to assist with the upcoming reporting obligations.

The EPA has also issued a revamped resource portal and reporting tool to streamline and simplify the process.

The CDR Rule requires manufacturers and importers to submit data every four years. This information on the manufacturing, processing and utilisation of chemicals is listed on the TSCA Chemical Substance Inventory.

For more information on CDR, please read the full article by H2 Compliance here and, for more support, reach out to H2 compliance here.

USA: TSCA new and existing chemical programmes

As reported previously, the US Environmental Protection Agency (EPA) continues to ramp up its new and existing chemicals programmes under the Toxic Substances Control Act (TSCA).

These developments aim to strengthen chemical safety regulations, improve the efficiency of review processes, and enhance public health protections by:

• Strengthening the Chemical Risk Evaluation Process (Finalized New Rule)
• Updating the New Chemicals Regulations (Proposed Rule – ongoing)
• Updating the TSCA Inventory, and
• Extending Significant New Use Rule (SNUR) activity

For more information on current and future developments, including potential further restrictions on methylene chloride, please read the full article on the H2 Compliance website.

If you need support with US TSCA regulations, please contact the services team in North America here.