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GB CLP Mandatory list updated for the second time

29 Mar 2024

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Following the notice that was issued last year to the World Trade Organisation Technical Barriers to Trade (WTO-TBT) Committee, the Great Britain Mandatory Classification List (GB MCL) has been updated with new and revised classifications for 25 substances.

The new classifications entered into force on 2nd March 2024 with a transitional period for companies to comply (the ‘compliance date’) until 2nd September 2025. The updated GB Mandatory classification and labelling list can be found here.

The notification to the WTO contained 26 substances, however only 25 of these have been added to the MCL. As was the case in the EU for the 21st ATP to CLP, the proposed classification for methyl methacrylate as a respiratory sensitiser has not been adopted as new information has been made available which may affect the classification. The HSE will now consider this new information using the Article 37A process, which allows them to develop and submit their own proposals for new and updated classifications rather than just reviewing the work of the ECHA Risk Assessment Committee (RAC), which has mainly been the case so far.

There is divergence from the EU harmonised classification for three substances included in the GB MCL:

Cinmethylin (ISO), CAS 87818-31-3
Transfluthrin, CAS 118712-89-3
Difenoconazole, CAS 119446-68-3

The GB classification for Cinmethylin was updated following the Article 37A process. An update to the EU harmonised classification for this substance is also currently in progress, with the RAC opinion expected to be published within the next 12 months. It should be noted that the proposals for EU classification often change between proposal stage and RAC opinion, so further divergence is possible.

Current EU / Old GB Classification

New GB MCL Classification

Proposed EU classification

Acute Tox. 4*, H332

Aquatic Chronic 2, H411

Skin Sens. 1; H317)

STOT SE 2; H371

Aquatic Acute 1; H400

Aquatic Chronic 1; H410

M(acute)=10

M(chronic)=1

Skin Sens. 1B, H317

STOT SE 3, H335

Aquatic Acute 1, H400

Aquatic Chronic 1, H410

M(acute)=10

M(chronic)=10

The other two substances that diverge are:

Substance

EU Classification (21^st ATP)

GB Classification

Transfluthrin

(CAS 118712-89-3)

Acute Tox. 4, H302

Carc. 2, H351

STOT SE 1, H370 (nervous system)

Aquatic Acute 1, H400

Aquatic Chronic 1, H410

EUH066

ATE (oral) = 580 mg/kg bw

M (acute)=1000

M(chronic)=1000

Acute Tox. 4, H302

Carc. 2, H351

Aquatic Acute 1, H400

Aquatic Chronic 1, H410

EUH066

ATE (oral) = 580 mg/kg bw

M (acute)=1000

M(chronic)=1000

The GB CLP Agency Opinion differs from the RAC Opinion for the classification STOT SE 1; H370 (causes damage to the nervous system). The Agency has considered the data and does not agree that the classification for STOT SE is supported by the available information.

Difenoconazole

(CAS119446-68-3)

Carc 2 H351

Acute Tox. 4, H302

Eye Irrit. 2, H319

Aquatic Acute 1, H400

Aquatic Chronic 1, H410

M(acute)=10

M(chronic)=10

ATE (oral) = 1 450 mg/kg bw

Acute Tox. 4, H302

Eye Irrit. 2, H319

Aquatic Acute 1, H400

Aquatic Chronic 1, H410

M(acute)=10

M(chronic)=10

ATE (oral) = 1 450 mg/kg bw

The GB CLP Agency Opinion differs from the RAC Opinion for the Carc. 2 hazard classification, on the basis that difenoconazole does not meet the classification criteria for carcinogenicity

It is also worth noting that the 21st ATP to the EU CLP Regulation included new or updated classifications for a further 27 substances that have not yet been added or updated to the GB MCL. This is likely to lead to further potential divergences between GB and the EU if the GB MCL is not updated to include these before the deadline for adoption of the 21st ATP (1st September 2025), at least for those entries where the EU list has been updated but the GB list has not.

Corrections to the entries for 5 substances were also made to the GB MCL following reports of errors. For each of these substances the statement EUH204 was deleted.

1,3-bis(1-isocyanato-1-methylethyl)benzene, CAS 2778-42-9
Bis(isocyanatomethyl)benzene, CAS 3634-83-1
2,4,6-triisopropyl-m-phenylene diisocyanate, CAS 2162-73-4
1,5-naphthylene diisocyanate [containing < 0.1 % (w/w) of particles with an aerodynamic diameter of below 50 µm], CAS 3173-72-6
1,5-naphthylene diisocyanate [containing ≥ 0.1 % (w/w) of particles with an aerodynamic diameter of below 50 µm], CAS 3173-72-6,

Details can be found in the version log to the GB MCL document.

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