On 20 June 2024, the HSE (Health and Safety Executive), the agency responsible for the CLP Regulation in the UK, published its opinions proposing the harmonised classification and labelling of seven substances. Two of these substances may be used in cosmetics: Benzotriazole and N,N’-Methylenebisacrylamide.
In both cases, the HSE issued opinions whose conclusions are identical to those of the ECHA (European Chemicals Agency) Risk Assessment Committee (RAC).
The classifications of these ingredients will therefore be the same on both sides of the Channel, but the implementation timescales will be different.
To date, these are only proposals that have yet to be formalised in the UK, whereas the classifications have already been agreed and are in the process of being adopted in Europe.
Both substances are on the list of those concerned by the 22nd ATP of CLP, notified in January 2024.
They will therefore be classified as follows.
Benzotriazole
• Identification: Chemical name: 1H-benzotriazole; No.CAS: 95-14-7; No.EC: 202-394-1; INCI: Benzotriazole; CosIng function: Antimicrobial
• Classification: Aquatic Chronic 2, H411 - Toxic to aquatic life with long lasting effects
• Pictogram, Signal word codet: GHS09 - Wng
N,N’-Methylenebisacrylamide
• Identification: Chemical name: N,N’-methylenediacrylamide; No.CAS: 110-26-9; No.EC:: 203-750-9; INCI: N,N’-Methylenebisacrylamide; CosIng function: Not reported
• Classification: Muta. 1B, H340 - May cause genetic defects
• Pictogramme, mention d’avertissement : GHS08 - Dgr
Sources
• GB MCL publication table (.xlsx), HSE, 20 June 2024
• Agency Opinion …
