Rationale for prioritising substances in the UK REACH work programme, 2022 to 2023

Published 30 June 2022

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The Department for Environment, Food and Rural Affairs (Defra) and the Scottish and Welsh Governments are the appropriate authorities for UK REACH. We (the appropriate authorities) worked with the Health and Safety Executive (HSE), the Environment Agency and stakeholders, such as non-governmental organisations (NGOs) and trade associations, to identify priorities for the UK REACH work programme in the financial year 2022 to 2023.

We used this exercise primarily to identify priorities for 2 types of activity in UK REACH:

We reviewed 17 proposals and identified the following 5 priorities for the 2022 to 2023 UK REACH work programme:

This document explains the rationale we used to identify these priorities. It also explains why some proposals were not adopted. We intend to reconsider these proposals when identifying priorities for future annual work programmes.

In addition, we may identify other activities to support the aims of UK REACH, such as commissioning projects to gather more evidence.

For any enquiries regarding this publication, contact us by email at: [email protected]

UK REACH forms part of the regulatory regime for chemicals in Great Britain (England, Scotland and Wales). It entered into force on 1 January 2021 after the UK left the EU and the EU REACH regulation was brought into UK law.

The statutory purpose of UK REACH is to ensure a high level of protection for human health and the environment in Great Britain. REACH stands for registration, evaluation, authorisation and restriction of chemicals.

Defra, the Scottish and Welsh Governments, HSE and the Environment Agency have together identified the priorities outlined below for the next annual UK REACH work programme. To do this, we considered proposals from various sources, including EU REACH (which remains a key information source), and sought views from across Defra and other government departments.

We conducted a series of focus groups to inform our priorities. Around 40 stakeholder organisations, such as NGOs and industry representatives, participated. The focus groups sought input on priorities as a whole and on individual proposals – including proposals suggested by stakeholders.

For the proposals we are not taking forward, this document provides the rationale behind why they are not considered a priority this year. We will continue to review the proposals not prioritised for action this year and reconsider them for regulatory action under UK REACH in future work programmes.

A proposal to investigate the risks of per- and polyfluoroalkyl substances (PFAS) and consider how best to manage any identified risks.

The Environment Agency, with HSE, is conducting an RMOA which will make recommendations on how to manage the identified risks of using PFAS. The appropriate authorities intend to act on the recommendations in the RMOA, when published, which may indicate that a restriction is the most appropriate option to control any identified risks.

Various hazards depending on the sub-group of PFAS: persistent, bioaccumulative, toxic (PBT).

PFAS are a large group of synthetic chemicals, consisting of several thousand individual substances. These substances are used in a wide range of product types, such as stain repellents, lubricants, packaging, electronics, and in fire-fighting foams, because they have several desirable technical properties (such as oil resistance, water resistance and low chemical reactivity).

However, their persistence in the environment means any adverse impacts may be difficult to mitigate. Long-term, some PFAS accumulate in living tissue (bioaccumulate) and can significantly affect human health and wildlife by causing cancer, interfering with hormonal systems (endocrine disruption) and some PFAS are toxic to reproduction. Many of those that are not bioaccumulative are still likely to accumulate in surface and ground waters, including drinking water supplies, where removal is difficult.

In March 2022 the European Chemicals Agency (ECHA) submitted a proposal under EU REACH to restrict PFAS in firefighting foams. Several EU member states also intend to submit a broader proposal in January 2023 to restrict the manufacture, placing on the market and use of PFAS.

Between December 2021 and January 2022, HSE conducted a call for evidence as part of the ongoing RMOA on PFAS under UK REACH. This provided an opportunity for interested parties to provide technical and socio-economic information on PFAS and inform development of the RMOA. Other areas of developing policy will also contribute to the RMOA, such as the work on persistent, mobile and toxic (PMT) substances.

The recommendations from the RMOA will be published on the HSE website in summer 2022, which may indicate that a restriction is an appropriate measure to control the identified risks. The appropriate authorities, with HSE, will consider the recommendations as soon as possible after publication.

A proposal to investigate the risks of intentionally added microplastics.

An evidence project to review emissions of intentionally added microplastics and the risks they pose (both to human health and the environment), including a socio-economic assessment.

While there is some uncertainty regarding the hazards involved, intentionally added microplastics are likely to be persistent in the environment and cause physical obstruction. They may also contain chemical hazards from additives in the plastics and absorb pollutants in the environment.

Intentionally added microplastics are often added to products, such as paints, infill material on sports pitches, and detergents, to serve a specific purpose. However, the risks that microplastics pose are not well characterised. Existing concerns relate mainly to environmental risks, but more recent studies suggest there are also risks to human health.

Some uses of intentionally added microplastics are already regulated within the UK. During 2018 and 2019 the four UK administrations separately introduced bans on microbeads in certain wash-off personal care products and cosmetics (which sometimes contain microbeads as exfoliants).

In January 2019 a proposal was submitted under EU REACH to ban the placing on the market of microplastics as a substance, on its own or in a mixture in a concentration equal to or greater than 0.01% weight for weight (w/w). Both the Committee for Risk Assessment (RAC) and Committee for Socio-economic Analysis (SEAC) under EU REACH agreed that introducing a restriction was the most appropriate measure to address the risks.

The Environment Agency submitted comments on behalf of several government bodies in response to the consultation on the 2019 EU proposal for restricting microplastics supporting the application of the precautionary principle (considering risk reduction measures when the risk is uncertain). They also stated that any measures adopted on this basis must be proportionate, based on cost-benefit analysis, and subject to review when new information becomes available.

Defra will commission an evidence project to assess the scale of the risks and identify the most effective measures to address them in the short to medium term. It will also help identify wider evidence gaps that need to be addressed in the longer term to support a more strategic approach to managing intentionally added microplastics.

A proposal to address the risks of formaldehyde emissions from consumer articles, particularly from manufactured wood, such as medium density fibreboard (MDF).

An RMOA to review the evidence base and evaluate options for a potential restriction.

Sensory irritation.

One of the most significant sources of formaldehyde emissions in homes is wood-based panels. European (including British) manufacturers of wood-based panels adopted a voluntary standard on formaldehyde emissions in 2007. However, panels manufactured outside the UK and EU are not always compliant, and any new restrictions are therefore likely to mainly affect imports.

In 2020 ECHA adopted a proposal to restrict formaldehyde and formaldehyde releasers in articles, primarily to address sensory irritation. Both the RAC and SEAC supported introducing a restriction. However, the analysis conducted for the EU proposal used simulated rather than measured data. As a result, HSE will need to assess whether the EU's data is sufficiently representative of the situation in Great Britain, or whether it will require more data specific to Great Britain.

During the prioritisation process, government departments and other stakeholders supported addressing the sources of formaldehyde. To determine the most appropriate measures to achieve this, HSE will review the evidence by conducting an RMOA. This will supplement other actions across government, such as the publication of guidance on indoor air quality and introduction of other regulations (such as the Construction Products Regulations 2022.

A proposal submitted by stakeholders to include other bisphenols in the existing restriction under UK REACH on the use of Bisphenol-A (BPA) in thermal paper.

An RMOA to review the evidence base and evaluate options for a potential restriction.

Endocrine disruption, toxic to reproduction, carcinogenic.

Bisphenols are commonly used to produce inks used in thermal papers. In particular, manufacturers use BPA as a colour developer.

BPA is already restricted in thermal paper under both EU REACH and UK REACH due to concerns over endocrine disruption and being toxic to reproduction. This is covered by entry 66 of Annex XVII in both versions of the legislation. However, a study conducted by ECHA showed that manufacturers are substituting BPA with other bisphenols with a similar hazard profile – such as bisphenol-S (BPS).

Expanding the existing restriction to other bisphenols will help prevent further regrettable substitution. It should also encourage manufacturers to move towards non-bisphenol thermal papers. It could also be an important step towards further protecting groups such as shop workers, who are disproportionately exposed to bisphenols when handling till receipts.

Information on the properties of various bisphenols is limited, and there are unresolved environmental risks to explore before initiating any measures to address the risks. There is also no direct EU precedent for this restriction, although one of the substances in the UK REACH rolling action plan for substance evaluation in 2022 is a bisphenol used in thermal paper.

HSE (with the Environment Agency advising on the environmental concerns) will therefore conduct an RMOA to review the available evidence in Great Britain and assess the scope of a restriction (if it is deemed appropriate).

A proposal submitted by stakeholders to address the risks of using hazardous flame retardants.

The Environment Agency will review and update its risk assessment on flame retardants, published in 2003, to feed into wider chemicals policy.

Endocrine disruption, neurotoxic, carcinogenic, toxic to liver, immune system, and kidney effects.

Chemical flame retardants are used in products to prevent or slow the development of fires. They are widely used in articles such as furniture, building materials and electronics. However, some groups of flame retardant are hazardous to both human health and the environment.

Several substances used as flame retardants are already subject to restrictions (under UK REACH and other regulations). In some cases, this has led to regrettable substitution with other substances that have similar hazard profiles. This is probably because previous action on flame retardants has concentrated on managing risks from individual chemicals (or small groups of chemicals) due to their impact on the environment.

The risks from some flame retardants are wide ranging, complex and cut across several human health and environmental issues. Therefore, any action to address the risks requires a coordinated approach between UK REACH and other policy areas, such as waste management and fire safety.

The Environment Agency, with input as required from HSE, will update with current evidence a previous report on the use of flame retardants in the UK and their possible impacts on the environment and human health. They will use this information to identify suitable groups of chemicals for further investigation and risk management, and to support the development of other chemicals policies.

A proposal to address occupational exposure to cobalt carbonate, cobalt di(acetate), cobalt dichloride, cobalt dinitrate and cobalt sulphate.

Carcinogenic and mutagenic.

Manufacturers use cobalt salts in a wide range of applications, including to manufacture batteries, surface treatments and in fermentation applications.

In 2018, a proposal was submitted under EU REACH to restrict the manufacture and placing on the market of the cobalt salts listed in concentrations equal to or above 0.01% by weight. RAC agreed a restriction was appropriate (with some modifications), but also proposed the EU Commission set a Binding Occupational Exposure Limit (BOEL – an upper limit on the concentration of hazardous substances allowed in the air).

HSE responded to the consultation on the EU proposal with the view that introducing an EU-wide BOEL would be more effective than a restriction. This view has not changed now the UK has left the EU. The European Commission has since stopped the procedure for introducing the ECHA restriction in favour of introducing occupational exposure limits (OEL) instead.

Within Great Britain, under the Control of Substances Hazardous to Health (COSHH) regulations, there is already a workplace exposure limit (WEL) for all cobalt and cobalt compounds of 0.1 milligrams per metre cubed (mg/m3) over an 8-hour time-weighted average (TWA). This legal limit on occupational exposure via inhalation applies to all cobalt compounds, including those listed in the ECHA restriction proposal.

Additionally, because the cobalt salts are identified as carcinogenic and mutagenic substances, COSHH requires that the exposure level is reduced to a level as low as reasonably practicable (ALARP). This reduces the exposure to below the WEL, to a level at which regulators expect to see workplace risks controlled within Great Britain.

If it is determined that specific additional risk management measures are required within Great Britain, this should be implemented in accordance with the COSHH regulations, as exposure primarily occurs in the workplace. However, Defra, the Scottish and Welsh Governments and HSE will together continue to consider any further evidence when prioritising substances for action under UK REACH in a future work programme.

A proposal to address occupational exposure to dimethylformamide (DMF).

Toxic to reproduction.

Industry commonly uses DMF as a solvent during the production of polymers, pharmaceuticals and some textiles, leather and fur. The primary route of exposure is therefore occupational.

In 2022 a restriction came into force under EU REACH (entry 76) on DMF as a constituent of other substances or in mixtures, unless manufacturers and downstream users take appropriate risk management measures. An example of such measures would be limiting inhalation to 6mg/m3 and exposure via the skin to 1.1 milligrams per kilogram per day (mg/kg/day). The restriction will apply across the EU from 12 December 2023.

DMF is already subject to a WEL within the UK, which limits long-term exposure to 15mg/m3 and short-term exposure to 30mg/m3. COSHH also requires employers to assess the risks of exposure (via all routes including the skin) to hazardous substances. They must then identify and implement measures to further reduce exposure, in proportion to the health risk, regardless of the existence of exposure limits set by the regulation.

If it is determined that specific additional risk management measures are required within Great Britain, this should be implemented in accordance with the COSHH regulations as exposure primarily occurs in the workplace. However, Defra, the Scottish and Welsh Governments and HSE will together continue to consider the evidence gathered under EU REACH for these substances when prioritising substances for action under UK REACH in a future work programme.

A proposal to restrict the placing on the market of rubber granules and mulches as infill material on synthetic turf sports pitches or in loose form on playgrounds.

Carcinogenic.

Rubber crumb, used in sports pitches, is often produced from end-of-life tyres. There was a concern in the EU that this could lead to rubber crumb containing high levels of PAHs, leading to a risk for users of synthetic turf pitches and some playgrounds.

Entry 50 of Annex XVII under UK REACH already restricts the use of extender oils in the production of rubber tyres if they contain more than 1 milligram per kilogram (mg/kg) of some PAHs (and 10mg/kg in total). Substances classed as category 1A or 1B carcinogens (known or presumed carcinogenic in humans) and listed under appendix 1 or 2 (including PAHs) are also restricted under entry 28 of Annex XVII.

In 2022 an amendment to entry 50 of the Annex XVII of EU REACH came into force limiting PAHs to 20mg/kg in granules or mulches used as infill material in synthetic turf pitches or in loose form on playgrounds or in sport applications. The amendment applies from 10 August 2022.

Data submitted to the public consultation on the ECHA restriction indicated that at least 95% of the material in use within the UK falls within the limit set in the 2022 amended entry 50 of Annex XVII under EU REACH. A study conducted for the ECHA restriction dossier similarly found that most pitches across the EU (and including the UK) are already compliant with the restriction.

In 2020 the Sports Pitch Construction Association (SAPCA) introduced a code of practice setting a concentration limit of 20mg/kg in rubber infill material manufactured by its members. The aim is to reduce the use of infill material that is non-compliant with the concentration limits set by the EU restriction. SAPCA continues to work closely with the UK government on this issue.

The effectiveness of existing restrictions on PAHs and the precautionary measures taken by the sports sector means this is not a priority for action this year. However, the appropriate authorities will continue to consider whether a restriction under UK REACH may be required when setting priorities in future work programmes, should evidence suggest the voluntary code is not being adhered to.

A proposal to address the risks to the public from lead exposure through direct contact and, predominantly, indirect environmental contact from emissions during PVC articles’ service life, treatment, and disposal as waste.

Toxic to reproduction, neurotoxic.

Lead-containing compounds can be used to stabilise PVC. However, the European PVC industry has voluntarily phased out the use of lead in PVC. This means that since 2015, virgin PVC produced in the EU (and the UK) should not contain lead. This restriction would only affect imports of lead-containing PVC from outside the EU.

In 2016 a proposal was submitted under EU REACH to restrict the use of lead compounds in finished articles produced from polymers or co-polymers of PVC. However, the European Parliament vetoed the proposal in 2020, which means the EU Commission must submit a revised proposal.

The RAC opinion on the proposal concluded that PVC is a minor source of indirect exposure to lead via the environment, when compared with other sources such as lead shot (HSE have recently published a restriction dossier on lead in ammunition). The EU have also identified a potential restriction on PVC and its additives in the Restrictions Roadmap under the Chemicals Strategy for Sustainability (expected in 2022).

Due to the voluntary limits adopted by the PVC industry (equivalent to the EU REACH restriction), the appropriate authorities have decided this is not a priority for action this year. However, the appropriate authorities will monitor wider investigations into the risk posed by substances (including lead) in PVC.

A proposal to prevent sensitisation to substances in textile and other articles that come into direct and prolonged contact with the skin and to prevent allergic contact dermatitis in those who are already sensitised.

Skin sensitisation.

Hazardous substances are often found in textiles as impurities from the manufacturing process, but some are intentionally added to change their properties.

Category 1A and 1B carcinogenic, mutagenic and reprotoxic (CMR) substances are already restricted under entry 72 of Annex XVII in clothing (and related accessories), textiles that under reasonably foreseeable conditions come into contact with the skin, and footwear. Also, entry 43 of Annex XVII restricts certain dyes detectable at concentrations above 30mg/kg (or 1,000mg/kg if listed in Appendix 9 of Annex XVII) in textiles and leather that come into direct contact with the skin.

In 2019 a proposal was submitted under EU REACH to limit the concentration of substances classified under the Classification, Labelling and Packaging (CLP) regulations as skin sensitisers. Both RAC and SEAC under EU REACH agreed that a restriction is the most appropriate measure to address the risks.

HSE submitted comments to the consultation on the proposal questioning how many skin sensitisers remain in finished textiles (and so present a risk). They also expressed concern over the lack of available analytic methods for detecting some of the substances in scope of the restriction and some of the assumptions made on the exposure scenarios. These concerns remain now that the UK has left the EU.

While this is not a priority for action this year, future work in this area may include reviewing the evidence base within Great Britain. The appropriate authorities may then consider taking action on a smaller subset of skin sensitisers in a future prioritisation exercise.

A proposal to introduce concentration limits on hazardous substances in disposable nappies.

Skin sensitisation, endocrine disrupting, carcinogenic, toxic to reproduction.

There is a possibility that trace amounts of hazardous substances could be present in disposable nappies as a result of the manufacturing process or impurities in the raw materials.

Some substances in scope of the EU proposal, such as certain phthalates, are already restricted in UK REACH under entries 51 and 52 of Annex XVII in ‘childcare articles’ (defined in the entry as including articles intended to facilitate hygiene). The proposal under EU REACH also identifies other substances of concern, such as PAHs and formaldehyde.

In 2020 France submitted a proposal under EU REACH to introduce concentration limits on substances found in disposable nappies. However, RAC concluded that the proposal is not justified because the risks were not demonstrated or characterised for several substances, including formaldehyde and PAHs. SEAC also concluded that the benefits were not demonstrated due to a lack of evidence.

HSE considers it highly unlikely that it would reach a different conclusion in UK REACH. The appropriate authorities will continue to keep this issue under review should any further evidence emerge, but this is not a priority for action this year.

A proposal by stakeholders to address the risks of hazardous substances in period products (including tampons, sanitary pads and menstrual cups), and to increase transparency of ingredients and test results from manufacturers.

Skin sensitisation, endocrine disruption, carcinogenic, mutagenic, toxic to reproduction.

There is a possibility that hazardous substances may be present in period products as a result of the manufacturing process or impurities in the raw materials. However, in addition some period products contain substances intentionally added to serve a specific purpose, such as to improve absorbency, and these have caused consumer concern due to potential hazards.

In a study into feminine hygiene products, the French Chemicals Agency (ANSES) did not find any risk associated with the presence of the substances tested. In addition, the Swedish Chemicals Agency (Kemi) concluded that the risk to human health from the majority of the substances tested was low. HSE are unlikely to come to a different conclusion under UK REACH.

There remain possible unresolved environmental concerns over disposable period products (such as resource use and waste). However, the appropriate authorities agreed that UK REACH is unlikely to be the most appropriate regulation to address these concerns.

A proposal to extend the existing restriction on the cyclic siloxanes octamethylcyclotetrasiloxane (D4) and decamethylcyclopentasiloxane (D5) in wash-off cosmetics (entry 70 of Annex XVII) to include dodecamethylcyclohexasiloxane (D6) and apply to leave-on cosmetics.

Very persistent, very bioaccumulative (vPvB) (D4, D5, D6); PBT (D4).

Industry uses D4, D5 and D6 to produce a variety of products, such as cosmetics (skin creams, deodorants), dry cleaning fluids, and various silicone polymers and gels used in construction, vehicle manufacture and polishes.

The Environment Agency prepared the original restriction dossier for D4 and D5 in wash-off cosmetics (entry 70 of Annex XVII) under EU REACH but did not consider there to be sufficient evidence to justify extending it to leave-on cosmetics. This view has not changed now that the UK has left the EU, although surveillance is ongoing through monitoring schemes performed by industry.

In 2019 ECHA submitted a proposal to extend the restriction on D4 and D5 to include D6 and to add leave-on cosmetics and other consumer/professional products. The Environment Agency submitted comments during the EU public consultation, highlighting the need to address the relevance of air emissions in more detail, but recognising the benefit of including D6 in the original restriction (its hazardous properties were not confirmed at the time of the UK proposal).

ECHA are also preparing to nominate D4 as a persistent organic pollutant (POP) under the Stockholm Convention. If successful, the substance would be banned as the UK is a signatory to the convention.

Norway has recently completed an evaluation of three linear siloxanes (close analogues of the cyclic siloxanes D4, D5, D6) because they are suspected of being PBT and vPvB. The evaluation concluded that they all meet criteria for addition to the candidate list of substances of very high concern (SVHC) and recommended that they be restricted under Annex XVII to prevent substitution for D4, D5 and D6.

It may therefore be most efficient to deal with D6, L3, L4 and L5 together, taking into account evidence of changes in the products supplied to the UK in response to the EU restrictions, as well as the level of environmental exposure within the UK. The appropriate authorities will continue to monitor the D4 POP nomination and any follow-up actions to the evaluations on L3, L4 and L5.

A proposal to restrict the manufacture and placing on the market of Dechlorane PlusTM.

Very persistent, very bioaccumulative.

Dechlorane PlusTM is a polychlorinated flame retardant found primarily in plastic coatings (such as wire coatings), plastic roofing materials and in materials such as nylon and polypropylene.

The Environment Agency nominated Dechlorane PlusTM as a SVHC under EU REACH. The agency proposed that authorisation was the most appropriate risk management route, given significant uncertainties in the use pattern and level of supply and apparently limited environmental exposure potential. Under the EU transition arrangements, Dechlorane PlusTM is on the UK SVHC candidate list.

In 2021 ECHA submitted a proposal under EU REACH to restrict the manufacture and placing on the market of Dechlorane PlusTM as a constituent, in a mixture or in an article at a concentration equal to or above 0.1% by weight.

Prior to this, in 2020, Norway nominated Dechlorane PlusTM as a POP under the Stockholm Convention. The Stockholm Convention Committee is currently preparing options for managing the risk of Dechlorane PlusTM, which will likely result in it being banned or restricted amongst signatories of the convention (including in the UK and EU).

Restrictions on substances under the Stockholm Convention take precedence over UK REACH restrictions and may render any work undertaken under UK REACH redundant. The appropriate authorities therefore agreed to await the outcome of the POPs nomination before deciding if additional measures are required under UK REACH.

A proposal to restrict 2,4-DNT being used or placed on the market as a substance in articles for supply to the public or professional workers.

Carcinogenic and mutagenic.

2,4-DNT is a substance used in manufacturing plastics. Manufacturers use 2,4-DNT as a plasticiser, in deterrent coatings and to produce pyrotechnics used in automotive safety applications.

Due to being a category 1B carcinogen, 2,4-DNT is already subject to a restriction under entry 28 of Annex XVII under UK REACH. It is also on the authorisations list (annex XIV) under UK REACH, meaning it requires approval from the Secretary of State for Environment, Food and Rural Affairs before it can be used in Great Britain.

There are no current authorisations for this substance under UK REACH or EU REACH, nor has HSE received any notifications of the import of this substance in articles. This suggests the substance is not currently used within the UK.

In 2021 a proposal was submitted under EU REACH to restrict 2,4-DNT from being placed on the market as a substance in articles for supply to the general public or to professional workers above a certain concentration (with derogations for explosives and military uses). RAC and SEAC are yet to form their opinions on the restriction dossier.

The appropriate authorities will therefore continue to monitor the proposal to restrict 2,4-DNT under EU REACH and consider any evidence of increased use, exposure and/or risk within Great Britain.

A proposal to investigate the risks of using lead in fishing weights and consider if a UK REACH restriction is required through an RMOA.

Toxic to wildlife by ingestion.

Fishing weights were historically made out of lead because it is readily available, inexpensive, dense and easily mouldable. However, lead is also highly toxic to both human health and wildlife.

In 2019 a proposal was submitted under EU REACH to restrict the use of lead in fishing sinkers and lures (as part of a restriction on the use of lead in projectiles). The prioritisation exercise therefore considered proposals to introduce additional measures on lead fishing weights (which are not within scope of the proposed restriction on lead in ammunition under UK REACH).

However, lead fishing weights between 0.06g to 28.35g were banned in England in 1986 (similar regulations apply in Wales and Scotland) and the evidence suggests that this ban has addressed the concern.).

Therefore, this is not a priority for action under UK REACH this year. However, the potential benefits of a restriction under UK REACH to address any uses relevant to fishing that fall outside the scope of the existing bans in Great Britain will be reconsidered when setting priorities in future years.

A proposal to restrict the use of calcium cyanamide in fertilisers.

Readily breaks down in a substance that is harmful to aquatic life.

Calcium cyanimide is used as a fertiliser, pesticide and in the manufacture of other chemicals.

In 2019 a proposal was submitted under EU REACH to ban the placing on the market of calcium cyanamide for use as a fertiliser. RAC concluded that a restriction is the most appropriate measure to address the risk across the EU. However, the SEAC concluded that it is uncertain whether the proposed restriction is the most appropriate measure.

There is uncertainty about the severity and extent of risk since no documented monitoring data was provided on which to assess the veracity of the risk assessment. There are also unresolved concerns about the alternatives that would be used in its place were it to be restricted.

The appropriate authorities will continue to monitor trends on the use of the substance within the UK. However, calcium cyanamide was not highlighted as a concern by any other policy teams involved in this process, and it is not considered a priority for action this year.