April 22, 2021
by Eleanor Grimes, Ph.D.
On Dec. 31, 2020, the U.K. copied across EU REACH Annex XVII (list of restricted substances) and implemented it into U.K. law as part of the REACH Amendment act. At this point any existing restrictions were copied into U.K. law. Any restrictions adopted by the EU from Jan. 1, 2021, were not automatically inserted and instead must be reviewed by the U.K. authorities.
On March 23, 2021, the U.K. government set out its first set of chemical restrictions to be reviewed and initiated by the U.K. authorities. Following on from recent work done in the EU, the initial set of work intends to look at lead ammunition and harmful substances found within tattoo inks. The Health and Safety Executive (HSE), with assistance from the Environmental Agency (EA), will introduce the restrictions if after public consultation it is deemed that these substances pose an unacceptable risk to human or environmental health.
Another group of substances to be looked at by U.K. authorities with regards to restriction are the per- and polyfluoroalkyl substances (PFAS). While some of this group including PFOA and PFOS are already restricted via the Persistent Organic Pollutants (POPS) regulation, they are a group of substances widely used in applications such as coatings, stain repellants and firefighting foams. Although many would consider them essential, concern continues to grow over the ability of PFAS substance to bioaccumulate in the environment and the impact this will have long term on human and environmental health.
Recommended Action Items
- Review the proposed restrictions for impact on your product line.
- Comment on the proposal when it is opened up.
Eleanor Grimes is a senior regulatory specialist whose role involves supporting clients via a variety of means including SDS authoring and special consulting projects. Her main region of expertise is in the EU and U.K. legislation.