HSE have published their latest bulletins:
Biocides
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EU active substance renewal submission deadlines: Apply for active substance renewal by the deadlines to keep products on the NI market
Under the EU BPR, active substance approvals will expire unless a renewal application is submitted at least 550 days before their expiry date.
The 550-day deadlines are coming up for the following active substance/product type combinations under EU BPR. This affects NI:
- 4-bromo-2-(4-chlorophenyl)-1-ethoxymethyl-5-trifluoromethylpyrrole-3-carbonitrile (Chlorfenapyr) (CAS 122453-73-0 EC n/a) in product type 08 (deadline 28 October 2023)
- Spinosad as a mixture of 50-95 % spinosyn A and 5-50 % spinosyn D (Spinosad) (CAS 168316-95-8 EC 434-300-1) in product types 18 (deadline 28 October 2023)
- 3-iodo-2-propynylbutylcarbamate (IPBC) (CAS 55406-53-6 EC 259-627-5) in product type 08 (deadline 28 January 2024)
- 3-phenoxybenzyl (1RS,3RS;1RS,3SR)-3-(2,2-dichlorovinyl)-2,2-dimethylcyclopropanecarboxylate (Permethrin) (CAS 52645-53-1 EC 258-067-9) in product types 08 and 18 (deadline 27 October 2023)
Any person, company or taskforce/consortium can support an active substance/product type combination for renewal – it doesn’t have to be the original supporter.
Check the EU Article 95 List to see who the original supporters were.
If a renewal application is not submitted for the above active substance/product type combinations under EU BPR, the approvals will expire. This means the active substances can no longer be used in biocidal products of the relevant product types in NI.
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EU active substance expiry dates: Biocidal products must be phased off the NI market
The active substance/product type combinations listed below are due to expire under the EU BPR on the following dates. This affects NI:
- 2,2-dimethyl-1,3- benzodioxol-4-yl methylcarbamate (Bendiocarb) (CAS 22781-23-3 EC 245-216-8) in product type 18 (deadline 31 January 2024)
Once the approvals expire, the active substances can no longer be used in biocidal products of the relevant product types in NI.
If you hold an affected EU BPR product authorisation or Control of Pesticides Regulations (COPR) product approval, we will contact you about cancelling or revoking your authorisation or approval. You will have an opportunity to submit comments or additional information and we will take account of these when finalising our decision.
If you are aware of any disproportionate negative effects that are likely to arise from the expiry of any of the active substance/product type combinations listed above, please contact us.
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EU active substance non-approval decision: Biocidal products must be phased off the NI market
Following evaluation/withdrawal of support under the EU BPR, a decision has been taken not to approve the following active substance/product type combinations. This will affect NI:
Biocidal products containing this active substance in the relevant product types can no longer be:
- supplied in NI after 26 June 2024; or
- used in NI after 26 December 2024
You must manage your stocks of the affected products to ensure they are removed from the NI supply chain by 26 June 2024. New treated articles containing this active substance in the relevant product types cannot enter the supply chain or be imported into NI after 23 December 2023. Treated articles that have entered NI supply chains before this date can continue to be supplied and used.
Find out more about treated articles. Any affected NI product approvals under the COPR will be revoked in line with the above dates. If you are aware of any disproportionate negative impacts that are likely to arise from the non-approval of any of the active substance/product type combinations listed above, please contact us.
Prior Informed Consent (PIC) Regulation
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Notifying exports of PIC chemicals for 2024: HSE, the GB PIC Designated National Authority (DNA), is inviting companies to submit notifications for exports of chemicals in the GB PIC List that are expected to take place during 2024.
The GB PIC Regulation requires the first export of a listed chemical in any calendar year, to any country, to be notified to the DNA at least 35 days before the intended date of export. Export includes the movement of a listed chemical from GB to Northern Ireland (NI).
Early notification ensures HSE has sufficient time to process notifications and seek the explicit consent of the importing country, where required, or to consider evidence for the granting of a waiver where there is no response to repeated requests for consent.
What you need to do
Export notifications
- Complete a GB PIC export notification form (.docx)
- You can find information on the notification process on HSE’s PIC website, as well as supporting guidance on how to complete the form (PDF)
- Please send completed forms to ukdna@hse.gov.uk
- To avoid delays in processing export notifications, please include the following details in the subject line of your email:
GB PIC – notification – company name – chemical/mixture – importing country name – 2024
- When submitting your export notifications, please attach only one export notification form and accompanying safety data sheet (SDS) to each email
- In addition to an SDS in English, please provide an SDS in the official language of the importing country, if available, or in one of its principal languages. If you do not attach an SDS, sections 4 and 5 of the form become mandatory
- Some countries have more than one DNA. To ensure HSE sends your notification to the relevant authority in the destination country, please be as accurate as possible in describing the foreseen use in the importing country (section 3.3 of the export notification form). This will also be helpful to the importing DNA when making decisions on consent, where applicable
- If you are intending to export a number of mixtures containing a chemical in the GB PIC List to the same importing country, where those mixtures differ only, for example, by colour and there are no differences in their classification and labelling or intended use, we can accept a single notification covering several mixtures
- Whenever changes in the concentration of PIC chemical(s) in a mixture trigger new labelling requirements, a new notification will be required
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Special reference identification numbers (RINs): Special RINs are required for PIC chemicals exported for the purpose of research or analysis in quantities of 10kg or less per exporter, per year and per importing country and are otherwise exempt from the requirements of the Regulation.
A Special RIN is also required where an importing country has waived its right to receive an export notification and has notified a positive import response under the Rotterdam Convention for the chemical being exported.
You can now submit Special RIN requests for 2024:
- Complete a Special RIN request form (.docx)
- Please send completed forms to ukdna@hse.gov.uk
- Please include the following details in the subject line of your email:
GB PIC – Special RIN request – company name – chemical/mixture – importing country name – 2024
- For exports of PIC chemicals to the EU, each Special RIN covers exports of up to 10kg of the substance for research and analysis purposes to each EU importing country
Classification Labelling and Packaging (CLP)
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ECHA public consultation: call for comments (Deadline: 22 September 2023)
The Great Britain Mandatory Classification and Labelling (GB MCL) process includes the consideration of information gathered from public consultations, conducted by HSE or international bodies such as the European Chemicals Agency (ECHA).
ECHA has announced public consultations on the following proposals for harmonised classification and labelling (CLH):
- 2-(4-tert-butylbenzyl) propionaldehyde (EC: 201-289-8; CAS: 80-54-6); 4-tert-butylbenzoic acid (EC: 202-696-3; CAS: 98-73-7); 3-(4-tert-butylphenyl)propionaldehyde (EC: 242-016-2; CAS:18127-01-0); 4-tert-butyltoluene (EC: 202-675-9; CAS: 98-51-1); 4-tert-butylbenzaldehyde (EC: 213-367-9; CAS: 939-97-9); methyl 4-tert-butylbenzoate (EC: 247-768-5; CAS: 26537-19-9). Chemicals registered under REACH. Health hazard class open for commenting
- p-cymene; 1-isopropyl-4-methylbenzene (EC: 202-796-7; CAS: 99-87-6); 3-p-cumenyl-2-methylpropionaldehyde; 2-methyl-3-(4-isopropylphenyl)propanal (EC: 203-161-7; CAS: 103-95-7); 3-(p-cumenyl)propionaldehyde; 3-(4-isopropylphenyl)propanal (EC: 231-885-3; CAS:7775-00-0); 4-isopropylbenzaldehyde; cuminic aldehyde (EC: 204-516-9; CAS: 122-03-2); 4-isopropylbenzoic acid; cuminic acid (EC: 208-642-5; CAS: 536-66-3). Chemicals registered under REACH. Health hazard class open for commenting
View the consultation on the ECHA website.
UK-based businesses with an interest in the proposal are strongly encouraged to share any relevant information. Scientific and technical information should be submitted directly to ECHA using their commenting webform by 22 September 2023. Comments will be published on ECHA’s website. If your business is affected by the GB CLP Regulation, please also consider if you are likely to be affected by the classification and labelling proposal and let us know at an early stage if you anticipate any significant impacts or benefits.
Information on wider policy and impact considerations can be submitted to HSE at GBCLP.GBMCL@hse.gov.uk.
Under the GB CLP Regulation, HSE will consider all published opinions of the Committee of Risk Assessment of ECHA (RAC) before publishing its own Agency Technical Reports and Agency Opinions, so any information you provide will be important in any final GB MCL decision.
More information on the new GB MCL system is available on the HSE website.
- 2-(4-tert-butylbenzyl) propionaldehyde (EC: 201-289-8; CAS: 80-54-6); 4-tert-butylbenzoic acid (EC: 202-696-3; CAS: 98-73-7); 3-(4-tert-butylphenyl)propionaldehyde (EC: 242-016-2; CAS:18127-01-0); 4-tert-butyltoluene (EC: 202-675-9; CAS: 98-51-1); 4-tert-butylbenzaldehyde (EC: 213-367-9; CAS: 939-97-9); methyl 4-tert-butylbenzoate (EC: 247-768-5; CAS: 26537-19-9). Chemicals registered under REACH. Health hazard class open for commenting
