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Issue 104 March 2024INFORMED COMMENT FROM THE BRITISH ADHESIVES & SEALANTS ASSOCIATIONCorrosive Chemical AacksHead to page 11 to read this arcle on corrosive chemicals to understand why everyone should be aware of the legislaon and useful links on the BASA website.11Safeguarding BiodiversityRead about how biodiversity plays a pivotal role in the chemicals sector and how the loss of biodiversity could have profound implicaons for the supply of crucial products.Regulatory OverviewBASA Consultant Caroline Raine gives you an update on what’s coming in 2024 and beyond in relaon to EU/UK REACH, Poison Centres, EU CLP and GB MCL.3 6BASA AWARDS NIGHT 2024 – FULL DETAILS COMING SOON!Get ready to mark your calendars and shine your shoes because BASA (Brish Adhesives and Sealants Associaon) is rolling out the red carpet for its inaugural Awards Night! It's me to celebrate the movers, shakers, and innovators in the adhesives and sealants sector like never before.Picture this: a gliering evening where industry tans and rising stars gather under one roof to honour excellence and achievement. From breakthrough innovaons to sustainable pracces, we're celebrang the outstanding contribuons of individuals and companies that drive our industry forward.But wait, there's more! This isn't just any awards ceremony – it's a chance to network with the best and brightest minds in the business. Rub elbows with industry leaders, forge new connecons, and gain insights that could take your career or business to the next level.And here's the best part: YOU can be a part of it all. Whether you're a seasoned veteran or a fresh face in the industry, there's an award category just waing for your name. Don't be shy – showcase your hard work, dedicaon, and ingenuity. Who knows? You could be the next big winner, taking home the coveted trophy and earning recognion from your peers.But even if you're not ready to take the spotlight, there's sll a way to get involved. Sponsor an award and show your support for the outstanding achievers in our community. It's a chance to raise your prole, align your brand with excellence, and give back to the industry that has given us so much.So, what are you waing for? Get ready to book your ckets, dust o your tuxedo or gown, and make history at BASA's rst-ever Awards Night. Enter an award, sponsor a category, and join us for an unforgeable evening of celebraon, inspiraon, and innovaon. See you on the red carpet!Bulletin

BASA Bullen Issue 1042CEO WelcomeDear BASA Members,As we reect on the past 12 months, I am grateful for your unwavering support and dedicaon to our associaon. Your commitment has been instrumental in driving BASA forward, even amidst unprecedented challenges over the last three years.I am pleased to announce that our relaonship with FEICA (the European Adhesive and Sealant Associaon) has never been stronger. Together, we have navigated the complexies of the post-Brexit regulatory landscape, ensuring that our members remain informed and prepared for whatever the future in Europe may hold. BASA connues to dedicate resources on the UK (in respect of Great Britain) regulaons as these diverge from the EU. Meeng the challenges of dual regulaon can be a nightmare and myself and the regulatory team are on hand to help you all. This is an important membership benet, so please take advantage of it.Looking ahead, I am thrilled to announce this year’s annual Sports Day is scheduled for the 19th of June. I encourage all our golfers and shooters to mark their calendars and book their places for their preferred events. And don't forget to stay for the presentaon dinner, where we will celebrate the spirit of camaraderie and compeon. We will be sending out some direct links to book your places aer the AGM held on 7th March. I would like to extend my hearelt thanks to our sports day sponsors IMCD, Newport Industries, and Omya for their connued support of this cherished event. Your contribuons make it possible for us to come together as a community and celebrate our shared passion for the industry.But that's not all! This year, we are excited to introduce a new addion to the BASA calendar: our inaugural Awards Dinner, scheduled for November. Plans are well underway, and I am condent that it will be an evening to remember. For further informaon, please turn to page 3, where you will nd details on how to get involved. We will be launching the awards process at our upcoming AGM, so if you missed this important occasion take a look at the dedicated website for the awards night. Let us celebrate the achievements of our members and inspire future excellence within our industry.Once again, thank you for your connued support and dedicaon. Here's to a bright future ahead for BASA and its members.Lorna WilliamsCEO, BASAThe aim of BASA is to be the umbrella organisaon for adhesive and sealant manufacturers in the UK and Ireland. BASA will support its members by represenng and promong the industry, oering guidance on technical and compliance issues, providing networking opportunies for members and providing members with support services.Technical/Regulatory Compliance• To inform members about the impact of UK and European legislaon• To oer industry posions about regulatory proposals• To provide advice about informaon sources• To deliver training about key issues to membersPromong the Industry• To posively project the social and economic benets of the adhesives andsealants industry to government, consumers and industryBASA Mission• To posively project the sustainability of our products• To foster academic/industry links (careers, research)• To promote the use of adhesives/sealants and the choice of member companies• To oer guidance to end users in the correct selecon and use of adhesives and sealants• To seek opportunies to promote the industry to schools and further educaon including vocaonal training organisaons, with a view to encouraging new entrantsNetworking opportunies for members• To provide business, technical, social networking opportunies for members• To provide a plaorm for members to meet/discuss issues of industry concern• To provide opportunies for members to discuss toll manufacturingUK Representaon• Interact with other business organisaons, trade associaons, government and NGOs to represent industry views according to Council guidelinesEuropean Representaon• To maintain our leading role within FEICA, acvely parcipang in FEICA commiees and contribung to seng its agenda to ensure members’ best interests are represented, according to Council guidelines• To inform members about European technical/regulatory issuesSupport Services: Providing Members With:• Training seminars for members• Anity partners programme

3 BASA Bullen Issue 104Save The Date: BASA SPORTS DAYHawkstone Park Hotel & West Midlands Shoong Ground, ShropshireIn the dynamic landscape of modern industry, the relaonship between biodiversity and the chemicals sector is oen overlooked. However, the intricate connecon between the two is undeniable. From the manufacture of formulated chemical products to the maintenance of sustainable supply chains, biodiversity plays a pivotal role. Understanding this relaonship is essenal, as the loss of biodiversity could have profound implicaons for the supply of crucial products.The Intersecon of Biodiversity and Chemicals ManufacturingThe chemicals industry encompasses a vast array of products, from adhesives and sealants to pharmaceucals and ferlizers. Many of these products rely on natural resources obtained from diverse ecosystems. For instance, organic compounds extracted from plants serve as raw materials for various chemical formulaons. Moreover, biodiversity provides essenal ecosystem services such as pollinaon, water puricaon, and soil ferlity, which are vital for agricultural and industrial processes.Formulated Chemical Products and BiodiversityFormulated chemical products, including adhesives and sealants, are engineered to meet specic performance criteria. These products oen contain a combinaon of synthec and natural ingredients. The loss of biodiversity can disrupt the availability of natural resources used in these formulaons. For example, if a plant species crucial for producing a specic chemical compound becomes exnct or endangered due to habitat destrucon, it Safeguarding Biodiversity: The Crucial Link with the Chemicals Industrycould lead to supply chain disrupons and increased producon costs.Supply Chain VulnerabiliesBiodiversity loss can create vulnerabilies in the supply chains of formulated chemical products. As ecosystems degrade and species decline, the availability of raw materials becomes uncertain. This uncertainty can manifest as price volality, regulatory hurdles, and logiscal challenges. For instance, restricons on the extracon of certain natural resources due to conservaon eorts can limit the availability of key ingredients, leading to producon delays and shortages.Sustainable Pracces and Biodiversity ConservaonTo migate the risks associated with biodiversity loss, the chemicals industry must embrace sustainable pracces. This includes adopng environmentally responsible sourcing strategies, invesng in biodiversity conservaon iniaves, and exploring alternave raw materials. By priorizing biodiversity conservaon, companies can safeguard their supply chains while contribung to the preservaon of ecosystems and species diversity.Collaboraon and InnovaonAddressing the challenges posed by biodiversity loss requires collaboraon and innovaon across the chemicals industry and beyond. Collaborave eorts between manufacturers, government agencies, non-governmental organizaons, and academic instuons can lead to the development of sustainable soluons. This may involve leveraging technology to opmize resource use, promong circular economy principles, and supporng reforestaon and habitat restoraon projects.ConclusionThe relaonship between biodiversity and the chemicals industry is mulfaceted and indispensable. From sourcing raw materials to ensuring product availability, biodiversity underpins the resilience of supply chains for formulated chemical products. As global biodiversity connues to decline at an alarming rate, it is imperave for the chemicals industry to priorize sustainability and biodiversity conservaon. By doing so, stakeholders can not only safeguard their business interests but also contribute to the preservaon of the planet's natural heritage for future generaons.JUNE 192024

BASA Bullen Issue 1044A quick guide to disclosing your climate impactIn an era where environmental consciousness is no longer a choice but a responsibility, businesses are facing increasing pressure to be transparent about their carbon footprint. As governments worldwide ghten regulaons and consumers demand eco-friendly pracces, the need for accurate and comprehensive carbon calculaons has never been more crical. The queson echoing through boardrooms and execuve suites is: Does your business have its carbon calculaons ready to report?Why start carbon reporng now?Carbon reporng has evolved from a mere trend to a regulatory necessity. Governments and regulatory bodies globally are instung stringent requirements for manufacturing businesses to disclose their carbon emissions and sustainability eorts. Key regulatory driversSeveral major regulatory frameworks are shaping the landscape of carbon reporng, urging product-led businesses to take acon:1. UK’s Streamlined Energy and Carbon Reporng (SECR): SECR applies to quoted companies, large unquoted companies, large limited liability partnerships (LLPs), and academy trusts. SECR requires companies to collect and report global Scope 1 and 2 GHG emissions. Scope 3 emissions reporng is voluntary, but recommended. In addion, companies must disclose at least one emissions intensity rao - emissions factors that compare emissions data with an appropriate business metric or nancial indicator, such as CO2e per employee or million £ in turnover. 2. EU’s Corporate Sustainability Reporng Direcve (CSRD)The new CSRD law came into force in January 2024. It requires all large companies and listed SMEs that operate in the EU to report on their climate impact – and begin publishing regular reports in 2025 for the nancial year 2024. The CSRD establishes a baseline of reporng for all companies. That includes the full climate requirements, which go further than the TCFD framework, which they are based on. They include measurement and disclosure of a company’s full Scope 1, 2 and 3 emissions, an assessment of climate risks, and policies related to climate change migaon and adopon.3. UK’s Sustainability Disclosure Requirements (SDR)In August 2023, the UK Government introduced the UK Sustainability Disclosure Standards (SDS) within the SDR framework. The SDS will form the basis of any future requirements in UK legislation or regulation for companies to report on risks and opportunities relating to sustainability matters, including risks and opportunities arising from climate change.UK SDS will be based on the IFRS Sustainability Disclosure Standards issued by the International Sustainability Standards Board (ISSB). By using the IFRS Sustainability Disclosure Standards as a baseline, the aim is that the information companies disclose under UK SDS will be globally comparable and decision-useful for investors.4. EU’s Empowering Consumers for the Green Transition (ECGT)In January 2024, the European Parliament gave its final greenlight to the new Directive on ECGT. The new law aims to curtail a series of unfair company tactics that prevents consumers from making sustainable choices. The text, agreed upon in negotiations among EU institutions and member states, is now ready to be transposed into national legislation across the EU.Once enforced, the Directive will ban a series of greenwashing tactics, including climate neutral claims, which are among the most misleading green claims on the market. In addition, producers will only be allowed to mark a product as “eco” or “green” when the entire product is truly greener than conventional ones and certified by a trustworthy scheme such as the EU Ecolabel. More rigorous oversight will also extend to sustainability labels, which will need to be backed up by third-party verification to ensure their credibility and reliability.5. UK’s and EU’s Carbon Border Adjustment Mechanism (CBAM)The UK government announced that it will introduce a CBAM by 2027. It will establish a carbon tax on imported goods targeted at a series of key emissions-intensive industries, with the purpose of equalising the carbon price paid by UK producers with those outside the UK and avoiding “carbon leakage” or the shifting of production of carbon-intensive goods to jurisdictions with less stringent emissions reduction policies. Further detail, including the precise list of products in scope, will be the subject of consultation in 2024.The EU recently adopted a CBAM to equalise carbon prices on imports with its own ETS system. While carbon pricing under EU CBAM will commence on January 1, 2026, a transitional phase is set until the end of 2025, during which only reporting obligations will be enforced.

5 BASA Bullen Issue 104As organisaons embark on the crucial journey of disclosing their carbon footprint, it’s important to remember that beyond regulatory mandates, transparent carbon reporng emerges as an indispensable step toward fostering a sustainable business. Embracing this responsibility not only ensures compliance but posions businesses as trailblazers in an era where sustainability is the cornerstone of corporate resilience and success. What steps can you take to ensure your business is ready for carbon reporng?1. Understand applicable regulaons: Stay informed about the specic reporng requirements relevant to your industry and locaon. Subscribe to informave news outlets and set Google alerts for the climate legislaon your business could be subject to in the future.2. Conduct a carbon audit: Evaluate your carbon emissions across Scopes 1, 2, and 3. It’s important to be ready for disclosure requirements when they come and to not fall behind. Invesng in specialised tools and professional help to conduct assess your carbon footprint could save me and resources, whilst providing condence in your results.3. Invest in data quality: Strengthen data collecon processes to ensure the accuracy of your environmental data. Consider implemenng soware soluons that streamline data management. Make sure to assign responsibility and accountability for each data collecon area. 4. Stay exible: Prepare for changes in regulaons and reporng standards. Maintain a exible reporng infrastructure that can adapt to evolving requirements. Ulising a carbon accounng soware soluon can migate the risk of being stac when it comes to calculaons and processes. Be strategic, forward thinking and understand that carbon management is a journey.5. Communicate transparently: Embrace transparency in your reporng. Clearly communicate your emissions, reducon iniaves, and sustainable pracces to build trust with stakeholders – both internally and externally. Invest in employee upskilling to ensure your workforce understands the importance of carbon data collecon and reporng.Reach out to the xtonnes expert team to nd out more about support for your business with its carbon reporng.Immy MobleyImmy.m@xtonnes.com

BASA Bullen Issue 1046Regulatory Overview – what’s coming in 2024 and beyond?2024 promises to be another full-on year with regards to chemical compliance. Divergence from EU is becoming more prevalent, and this is set to connue and rapidly increase in 2024 and beyond. So, let’s look at what is coming in 2024 with regards to REACH, both UK and EU REACH and CLP, both GB and EU CLP.Let’s start with REACH.EU REACHThe EU REACH revision is on hold now, due to European Parliamentary Elecons, and whilst this pause is welcome, it brings some uncertaines and there are a few topics that may impact members: the concept of the Mixture Assessment Factor (MAF), polymers registraons under REACH and the Generic Risk Approach. We are working closely with FEICA on these topics and will connue to feed our concerns into ECHA. The REACH fees model is also likely to be reviewed.Otherwise, it is business as usual with REACH, dossiers must be kept up to date and companies must ensure that they monitor their substances with all the relevant lists. Note that the candidate list was just recently updated with a further ve substances in January 2024. BASA’s Watch List can help you monitor your substances, so be sure to check that out if you haven’t already!UK REACHThe REACH (Amendment) Regulaons 2023, SI 2023 No. 722 were published in 2023 which formally extends the UK REACH deadlines by amending Arcle 127. The deadlines are now conrmed as;Deadline (last date for dossier submission)27 October 202627 October 2028 27 October 2030 Tonnage1000 tonnes or more per year 100 tonnes or more per year 1 tonne or more per year Hazardous property• Carcinogenic, mutagenic or toxic for reproducon (CMRs) - 1 tonne or more per year• Very toxic to aquac organisms (acute or chronic) - 100 tonnes or more per year• Candidate list substances (as at 31 December 2020) Candidate list substances (as at 27 October 2023) We do not yet know what REACH registraon will consist of, but a consultaon, along with more informaon is expected in quarter 1 of 2024 – i.e. soon! Again, we will let members know when it is released and will give you some guidance on what it means, and how to respond. In the meanme, if you have not yet submied your Downstream User Import Nocaons (DUINs) please do them as soon as possible, They protect your business and allow you to benet from the transional registraon dates.EU Poison centresThose of you that did your nocaons under the ‘exisng” member states requirements have unl the 1st January 2025 to make your Annex VIII harmonised poison centre nocaons. EU CLPThe 21st Adaptaon to Technical Progress (ATP) to the Regulaon on the classicaon, labelling and packaging of substances and mixtures (CLP) has been published. Commission Delegated Regulaon (EU) 2024/197 of 19 October 2023 amending Regulaon (EC) No 1272/2008 as regards the harmonised classicaon and labelling of certain substances.This Regulaon entered into force on the 25th January 2024 and it applies from 1 September 2025. The full text of the ATP can be found here:https://eur-lex.europa.eu/eli/reg_del/2024/197/oj Note that 1.2-Benzisothialzol-3(2H)-one (BIT), Dibutyln maleate; 2,2-dibutyl-(1,3,2-dioxastannepin-4,7-dione) and Dibutyln oxide are all impacted.The 22nd Adaptaon to Technical Progress (ATP) to the CLP Regulaon, Regulaon (EC) No. 1272/2008 has been noed to the World Trade Organisaon, Technical Barriers to Trade (WTO-TBT) Commiee. The 22nd ATP introduces changes to Table 3 of Part 3, Annex VI to the CLP Regulaon, the list of harmonised classicaon and labelling entries. The update includes amending 42 substances or substance groups and by deleng one entry.It closes for comment on the 15th March 2024 and can be found here :https://eping.wto.org/en/Search/Index?viewData=%20G/TBT/N/EU/1042 Adopon is expected in quarter 2 of 2024.Work is now ongoing on the 23rd and 24th ATPs.

7 BASA Bullen Issue 104In addion;• Line spacing: the distance between two lines shall be equal or above 120 % of the font size• Contrast: text must be black on white background• Typeface: single font, easily legible, without serifs• Leer spacing: appropriate to be legibleWe will let you know once these are formally agreed, and the regulaons published.Capacity of the package≤ 0,5 L≤3 L≤50 L≤500 L>500 L Dimensions of the label (in millimetres) for the informaon required by Arcle17If possible, at least 52x74At least 74x105At least 105x148At least 148x210Dimensions of each pictogram (in millimetres)Not smaller than 10x10If possible, at least 16x16At least 23x23At least 32x32At least 46x46 Minimum font-size (x-height in millimetres)1.21.41.82.02.0GB MCLAnd nally, GB MCL.The Great Britain Mandatory Classicaon list (GB MCL) has been updated with new and revised GB MCLs for 98 substances. The entry into force date was the 20th October 2023 and the compliance date is the 20th April 2025.The GB Mandatory classicaon and labelling list can be found at: www.hse.gov.uk/chemical-classicaon/assets/docs/mcl-list.xlsx The HSE GB CLP publicaon table can be There is also a revision to EU CLP that is imminent. The dra has been agreed and we now wait for it to be formally published. (So, it is subject to revision). It includes changes to;• More than One Constuent Substances’ (MOCS)• The Grouping Approach• Nocaon rules• Rules for updang labels• Rules on rell sales• Digital labelling And it will have new font sizes for EU CLP labels; found here www.hse.gov.uk/chemical-classification/assets/docs/publication-template.xlsx A second update is imminent. The nocaon sent to the World Trade Organisaon contained 26 substances, with proposed adopon in Q1 2024 and mandatory entry into force Q3 2025. More informaon, including a list of the 26 substances and their proposed classicaons can be found here: hps://eping.wto.org/en/Search/Index?viewData=%20G/TBT/N/GBR/67 This means that we currently have 13 substances which have a classicaon in GB that is dierent to the EU classicaon. As we see the EU publish more ATPs and as the HSE updates the GB MCL this is only going to increase. Please remember that we have a substance watch list to help you review and monitor your substances and the weekly drop-in clinics are open to all members. If you have any quesons please feel free to get in touch. Arcle wrien by Caroline RaineUPDATE

BASA Bullen Issue 1048ChemTrust - Connued Divergence of UK and EU on SVHCsChemtrust have stated that in the four years since Brexit, the EU has added 31 new chemicals to its substances of very high concern (SVHC) watchlist while the UK has added zero. The latest update to the EU's SVHC list added a further 5 more substances, but UK ministers have said not to expect any new addions to their version unl 2025 at the earliest.Inclusion on the SVHC list requires companies to provide informaon to consumers about a substance's safety. It also sends a signal that industry needs to start looking for alternaves ahead of a possible ban.Chloe Alexander, senior campaigner at the charity CHEM Trust, said “We are increasingly seeing the UK’s post-Brexit regulaon of chemicals standing sll as the EU introduces new protecons from harmful chemicals,” adding that “people and the environment in Britain will have greater exposure to harmful chemicals than in the EU and a second-rate system for regulang chemicals.”A spokesperson for Defra, meanwhile commented “There is no reducon in our high levels of chemical protecon — with UK regulaons retaining both the fundamental approach and key principles of the EU regulaon.“By assessing the risks of each substance, we will ensure that we have a clear raonale for which substances are added to the UK REACH Candidate List, ensuring we beer protect human health and the environment.“As part of a wide program of work, we are currently assessing four possible substances to be added to our candidate list. UK REACH is not the only tool by which we can take acon on substances, with risks being addressed through a range of robust regulaons.” BASA Editorial comment: Manufacturers of adhesives and sealants regularly reformulate products to remove substances of concern and will always try to formulate the safest possible products to meet the funconal and performance requirements. The reality is that manufacturers in the UK are not operang in a bubble, and many manufacturers are part of a global market and take stock of all available informaon before placing product on the market. Implying that the post Brexit reality is that there is a greater exposure to harmful chemicals is not one that we recognise in our sector, and we would agree that a sensible approach is to assess the actual risks and exposure to any chemical substance. Divergence is problemacal for formulators of chemical products, and creates costs, but there is no evidence that this divergence is leading to greater exposure to harmful chemicals. Construcon Products Associaon NewsThe CPA has published new guidance: 'Golden Thread - How to Provide Informaon under the Building Safety Act 2022 and The Building (Higher-Risk Building Procedures) (England) Regulaons 2023'.Under the new “gateway” approach to ensure that building safety is considered at each stage of a building’s design and construcon, a “Golden Thread” of informaon needs to be compiled. The “Golden Thread” provides an audit trail throughout the life of a building. This Guidance explores what acons are needed from construcon product manufacturers to provide informaon under this new approach. The guidance document is available here: https://www.constructionproducts.org.uk/publications/technical-and-regulatory/cpa-guidance-golden-thread-how-to-provide-informaon/

9 BASA Bullen Issue 104BASA Working Group round up The core of the acvies within BASA, on behalf of our industry, are undertaken through our working groups. Perhaps not surprisingly, in this post EU Exit era, where we have to stay abreast of not only the developments in the UK but also the EU as well as worldwide, the Chemical Legislaon Working Group (formerly known as the Health & Safety Working Group) and the Environment and Sustainability Working Group have had the heaviest workloads and consequently the biggest outputs in terms of representaonal acvies, guidance documents and posion papers, all of which can be found on the BASA website. The Chemical Legislaon Working Group have issued mulple guidance documentscovering subjects including EU and UK REACH, EU and UK CLP, and Poisons Centres, as well as advising on the growing divergence between EU and UK chemicals legislaon.The Environment and Sustainability Working Group have also been busy following topics including carbon accounng and the approaches to achieving the governments ‘net zero’ target, the developing extended producer responsibility legislaon, with the divergent approaches around Europe to that of the UK. Plus, the environmental impact of microplascs and plasc pellet losses and the mass balance approach to achieving sustainable feedstocks. A guide to ‘green’ claims has also been reviewed.Whilst the above two working groups have been following the regulatory scene on behalf of the membership the Building Adhesives and Construcon Chemicals Working Group and the Sealants Working Group have been involved in the standardisaon work of those product groups and the developments of the EU and UK Construcon Products Regulaons, where there remains concern surrounding noed or approved body tesng capacity, in relaon to CE and UKCA marking, all of which could be resolved by a mutual recognion agreement.The principle focus of the Packaging Adhesives Working Group is around food contact materials, such as mineral oils. There is no specic legislaon in UK or EU concerning adhesive materials in contact with foods and so best pracce is guided by the regulaons concerning plascs and inks in food contact applicaons. There are also moves at EU level to create a harmonised one stop data base for all chemical substance hazard data. The work of all the Working Groups is coordinated and guided by the Technical Steering Commiee. To facilitate access to informaon for the members ‘Issues Maps’ that address all of the aforemenoned subjects and a collaon of the ‘Acve UK & EU Consultaons and Impact Assessments’ have been created on the website and are recommended as the rst place to begin any searches.Finally, the weekly drop-in clinics are open to all members and cover a wide variety of topics. They are all recorded and available for reference at your convenience on the BASA website.Arcle wrien by Jim Palmer

BASA Bullen Issue 10410UKCA Marking of Construcon Products – no news is not good news!The government announced at the end of 2022 that the deadline for ending recognion of the CE mark and moving to the UK alternave has been extended to 30 June 2025. Another announcement followed in 2023 from the Department of Business and Trade outlining the government’s intenon to extend recognion of the CE mark indenitely for the 18 product sectors they look aer, but this announcement did not include construcon products.At the end of 2022 we saw a U-turn on simplicaon measures that had been adopted by product manufacturers only six months earlier to allow the use of historical test reports from an EU noed body to issue your Declaraon of Performance (DoP). Where some simply missed the exempon around construcon products, others believed or assumed for policy reasons that the indenite extension to CE marking recognion would inevitably encompass construcon products given sucient me. Chaos resulted!Subsequent announcements in January 2023 have seen new product groups (vacuum cleaners, mobile phones, toys, and demolion explosives) able to rely “indenitely” on European safety marks to be sold in Britain. But again, disappoinngly, construcon products remain in a list with medical devices, marine equipment, rail products, cableways, transportable pressure equipment and unmanned aircra systems having to meet separate rules.Discussions connued with UK Government, via the Construcon Products Associaon and Construcon Leadership Council, where I represent BASA, but with no formal announcement over the last 12 months, I have no condence that the situaon will change for construcon products any me soon. As we move ever towards June 2025, we once more nd ourselves in a posion where to rely on a reversal of this policy remains a business risk. Of course, with the Building Safety Act, we are waing for the secondary legislaon that was promised, and we will then see whether the, now withdrawn, 2020 UK SI amending the exisng regulaon is further amended, or scrapped altogether in favour of a completely dierent proposal.For those who deal in products not covered by a designated/harmonised standard, the issuing of a UK technical assessment remains a voluntary process, however this relies on the use of a European Assessment Document, and this process is sll not completely clear if double tesng is to be avoided.In the absence of mutual recognion between UK approved bodies and European noed bodies it remains the case that there is no risk-free path forward in conformity assessments other than a complete duplicaon of tesng (for AVCP3 characteriscs) unless the manufacturer is exclusively pursuing trade in only one of these jurisdicons. New products are slightly easier to navigate, as an EUNB and a UKAB can work together to minimise duplicaon of the actual tests, however the administraon required to assess conformity to the standards carries an addional cost.We have some guidance documents available on the BASA members-only area of the website to summarise some of these aspects. Refer to the UKCA Marking of Construcon products Issues Map in the rst instance: www.basa.uk.com/WorkingGroups/ArcleDetails?arcleId=2059Independent Review of Building Regulaons and Fire SafetyThis review, led by Dame Judith Hacki, was a pivotal moment in the UK's approach to building safety following the tragic Grenfell Tower re. The report highlighted systemic failures in building regulaons, construcon pracces, and oversight mechanisms, ulmately calling for a holisc reform of the regulatory framework governing building safety.The Building Safety Act, which encompasses the provisions of the Building Safety Bill, seeks to address the key recommendaons including:• Creang a more robust regulatory framework: The Act aims to establish clearer roles and responsibilies for those involved in the design, construcon, and management of buildings, ensuring greater accountability for building safety.• Improving building safety standards: The Act introduces more stringent requirements for the design, construcon, and maintenance of high-risk buildings, including residenal high-rise buildings.• Enhancing oversight and enforcement: The Act empowers the new Building Safety Regulator to oversee compliance with building safety regulaons, invesgate incidents, and take enforcement acon against those responsible for breaches.• Strengthening resident engagement and rights: The Act aims to give residents a stronger voice in the management of their buildings and ensure they have access to essenal safety informaon.A DLUHC-commissioned independent review of the construcon products tesng regime by Paul Morrell OBE and Anneliese Day KCBASA set out recommendaons for industry and government alike to improve and strengthen the tesng regime for construcon products in April 2023. BASA have been inpung into the sector responses to the points raised in the review.Wrien by Lorna Williams

11 BASA Bullen Issue 104Corrosive Chemical Aacks – why you need to understand the legislaon? Aer the recent distressing corrosive substance aack in Clapham, it is probably useful to look at corrosive substance aacks, what they are, how oen they occur and the relevant legislaon. This violent use of throwing acid or alkali on to someone’s body with the intenon to harm or kill is what we mean by a corrosive substance aack and acids and alkaline-based substances are available from retailers, in store and online. Strong household cleaners contain strong acids and alkalis. Products such as bleach and oven cleaner are alkaline substances, but some related adhesive and sealant products may also contain strong acids and alkalis, so we should all be aware of the legislaon.According to the UK charity Acid Survivors Trust Internaonal (As), using freedom of informaon requests, gures show the police in England and Wales recorded 710 corrosive substance aacks in 2022, the most recent data available. This was up from 421 in 2021 during the Covid pandemic. They peaked at 949 in 2017 before new legislaon targeng the sale and possession of corrosive substances was introduced. NHS data for England shows 82 admissions to hospital in 2022-2023, and in earlier years an average of about 100 admissions a year. The region with the highest number of admissions in the most recent years was the north-west.New measures targeng aacks with corrosive substances came into force in 2022 and they were part of the Oensive Weapons Act of 2019, which introduced two new oences: selling a corrosive product (both over the counter and online) to a person under the age of 18; and possessing a corrosive substance in a public place without good reason or lawful authority.Possession of a corrosive substance in a public place carries a prison sentence of up to four years. It was already a crime under the Oences against the Person Act 1861 to use a corrosive substance with intent to inict grievous bodily harm. This oence carries a maximum sentence of life imprisonment in England, Wales and Northern Ireland.Part 1 of the Oensive Weapons act restricts access to the most harmful corrosive substances by under 18s by making it an oence to sell a corrosive product, whether over the counter or online, to someone under 18 years of age. The denion of a “corrosive product” is as provided by Schedule 1 of the Act, and is reproduced below:Some of the substances dened as corrosive products are commonly used in household products such as high strength drain cleaners/unblockers, paint strippers, brick and pao cleaners, cleaning products, rust or limescale removers. However, products such as normal strength household bleach and cleaners will not be caught by the age restricons on sales as they tend to be more of an irritant and do not contain corrosive chemicals at the concentraons set out in the Schedule. Sellers will, however, need to check their product ranges to ensure that they know which products meet the denion of a corrosive product and must not be sold to a person under 18.In the case of business-to-business supply and purchasing of corrosive products, the sale and delivery provisions would not apply as the sale is being made to a business and not to a person under 18. The only excepon is where a business is run by a sole trader who is under 18. In these circumstances, the sole trader would need to make arrangements for the corrosive products to be purchased by, and delivered to, a person who is over 18.It should be noted that these restricons are under the Oensive Weapons Act. Other legislaon (eg the 1972 Poisons Act) deals with poisons and explosives precursors, which may introduce addional restricons for substances like hydrochloric acid, which are also listed as a regulated explosives precursor and cannot be sold to any member of the public, even if they are over 18 years of age, without an Explosives Precursors and Poisons (EPP) licence issued by the Home Oce and an associated photographic identy document.See online version of this Bullen on the BASA website for the below useful links.BASA Working Group content (Members-only area of the website)GN100 - Sales of adhesives and sealants to under 18s - v1.0 Guidance Note - Mixtures containing explosives precursors and poisons from 1st October 2023Mixtures containing ≥ 10% Hydrochloric Acid – changes under the Control of Explosives Precursors and Poisons Regulaons 2023Guidance Frequently asked quesons: The Poison Act 1972 and the Control of Poisons and Explosives Precursors Regulaons 2023Home Oce Publishes Updated Guidance on Explosives PrecursorsThe Control of Explosives Precursors and Poisons Regulaons 2023UK Government GuidanceSupplying explosives precursors and poisons - Updated 29 November 2023Oensive Weapons Act 2019 PART 1 - Possession of corrosive substancesOensive Weapons Act 2019 – Statutory GuidanceName of substance and Chemical Concentraon limit (weight in weight) Abstracts Registry Number (CAS RN) Ammonium hydroxide (CAS RN 1336-21-6) 10% w/w Formic acid (CAS RN 64-18-6) 10% w/w Hydrochloric acid (CAS RN 7647-01-0) 10% w/w Hydrouoric acid (CAS RN 7664-39-3) 0% w/w Nitric acid (CAS RN 7697-37-2) 3% w/w Phosphoric acid (CAS RN 7664-38-2) 70% w/w Sodium hydroxide (CAS RN 1310-73-2) 12% w/w Sodium hypochlorite (CAS RN 7681-52-9) 10% w/w Sulfuric acid (CAS RN 7664-93-9) 15% w/w

BASA Bullen Issue 10412Navigang Post-Brexit Challenges: UK Chemicals Industry and Regulatory DivergenceAs the United Kingdom (UK) charts its course post-Brexit, one sector facing signicant challenges is the chemicals industry. With the end of the transion period, the UK now has the autonomy to shape its own regulatory framework. However, this newfound freedom comes with complexies, parcularly concerning chemicals and product legislaon. Navigang the divergence from EU regulaons poses substanal hurdles for businesses, requiring strategic planning and adaptaon. When you add challenges of the land border between Northern Ireland and the EU and the reality of NI following EU legislaon and GB diverging, it is easy to see the potenal for chaos!Regulatory Landscape Pre- and Post-BrexitBefore Brexit, the UK chemicals industry operated under the framework of European Union regulaons, primarily governed by the Registraon, Evaluaon, Authorizaon, and Restricon of Chemicals (REACH) regulaon. REACH provided a comprehensive system for the registraon, evaluaon, and authorizaon of chemicals, ensuring high standards of safety and environmental protecon.Post-Brexit, the UK established its own regulatory regime, UK REACH, to manage chemicals within its borders. While UK REACH mirrors many aspects of its EU counterpart, there are notable dierences, including registraon requirements, data sharing arrangements, and the role of regulatory authories. These variances introduce complexity and uncertainty for businesses operang in both the UK and EU markets, and again cause specic issues for Northern Ireland and the Republic of Ireland in terms of movement of goods.Challenges of Regulatory DivergenceOne of the primary challenges facing the chemicals industry post-Brexit is regulatory divergence between the UK and the EU. Misalignment in regulatory standards can create barriers to trade, increase compliance costs, and hinder market access. For businesses that export or import chemicals and formulated products, navigang divergent regulatory requirements adds layers of bureaucracy and administrave burden.Regulatory divergence raises concerns about maintaining product safety and environmental standards. Harmonizaon of regulaons between the UK and the EU ensured a consistent approach to risk management and compliance. Divergence risks fragmenng the regulatory landscape, potenally compromising safety and sustainability objecves.BASA is working hard to help member companies navigate this divergence, producing weekly clinics and guidance notes.Impact on BusinessesThe implicaons of regulatory divergence extend beyond administrave complexies. For businesses operang across borders, divergent regulaons necessitate strategic decisions regarding market priorizaon, supply chain management, and investment allocaon. Smaller enterprises, in parcular, may struggle to adapt to the addional regulatory burden, potenally liming their compeveness and growth prospects.Addionally, regulatory uncertainty undermines business condence and investment certainty. Rapid changes in regulatory requirements or lack of clarity on future regulaons can deter investment in research and development, innovaon, and infrastructure. Long-term planning becomes challenging in an environment characterized by regulatory ux.Strategies for AdaptaonIn navigang the challenges of post-Brexit regulatory divergence, the chemicals industry must adopt proacve strategies to ensure resilience and compeveness. This includes:1. Regulatory Compliance: Businesses must stay abreast of evolving regulaons in both the UK and EU markets, ensuring compliance with applicable requirements. BASA can help here. 2. Investment in Experse: Invesng in regulatory experse and capacity building is essenal for navigang complex compliance landscapes and managing regulatory risks eecvely. BASA can help to oset some of these costs with provision of limited support to member companies on specic quesons, and the provision of templates and guidance notes that may help migate some of the costs. 3. Collaboraon and Advocacy: BASA is ideally place to engaging with policymakers and regulatory authories to advocate for regulatory alignment where feasible and to inuence the development of future regulaons. 4. Diversicaon and Innovaon: Diversifying markets and supply chains and invesng in innovaon can migate the impacts of regulatory divergence and enhance compeveness in a changing regulatory environment.ConclusionThe UK chemicals industry faces signicant challenges in adapng to post-Brexit regulatory divergence. Navigang the complexies of divergent regulaons requires strategic planning, investment in experse, and proacve engagement with stakeholders. By embracing these challenges as opportunies for innovaon and adaptaon, the industry can posion itself for sustainable growth and compeveness in the evolving regulatory landscape. We at BASA help our member companies and provide an excellent return on the annual fees.

13 BASA Bullen Issue 104Sco Bader announces intent to invest £30m to transform Flagship UK manufacturing siteSco Bader UK, a Northamptonshire-based specialist in composite and adhesive materials, announces the intent to invest £30M to transform its agship UK manufacturing site. The ve-year programme will commence in 2024 with £8M earmarked for the rst phase of the works. This planned investment will support the group’s UK customers by making the plant more exible - enabling quicker lead mes and the rapid scaling up of an increasing number of sustainable alternaves to the Group’s current products as well as new performance products in areas such as 3D prinng.“The planned investment rearms our commitment to the UK composite supply chain and to all our colleagues, partners and associates that benet from our long-standing presence at Wollaston,” says Sco Bader’s CEO, Kevin Mahews. “In addion, the investment will upgrade our capability to connue to develop and supply new sustainable performance materials designed to help our customers on their journey to net zero.”This signicant commitment to the UK market will ensure the future of Sco Bader’s key product brands including Crysc® resins and gelcoats, Crestabond® structural adhesives and Crestapol® performance resins.Recent R&D investment - both in the UK and globally - has bolstered Sco Bader’s exploraon of more sustainable alternaves and innovaons that lead to the ‘lightweighng’ of composite parts for markets such as EV’s, renewable energy and land transportaon, as well as the development of bio-based ingredients for the personal care market. Alongside allocang the capital to transform its UK site, the company has also created a €2M laboratory facility in France, which will open in Q1 2024. Outside of Europe, Sco Bader’s two-year build of a $16M new manufacturing facility in Mocksville, USA, also becomes fully operaonal in 2024. These investments are designed to bring Sco Bader’s enhanced capabilies closer to its global customer base, helping with the longer term goal of shortening supply chains and lowering the carbon footprint associated with transporng goods. For further informaon visit www.sco.bader.comSTAND Q90 A message from Kieran Raerty, Rakem Group. My Brother Kevin very sadly passed away unexpectedly on Sunday 28th January 2024. Kevin's funeral was held on Friday 1st March at 12pm at St Osmund’s Church, followed by a service at East Lancashire Crematorium. Kev was the life and sole of many pares and I know he is relying on us to give him the send o he deserves. If you would like to make a donaon in Kevin’s memory to one of his and Emma’s chosen charies, or to leave condolences for his family and friends, you can do so at the online memorial page linked below. Thank you to everyone who has already sent cards, owers and messages of support, they have been very much appreciated. https://kevinrafferty.muchloved.comTribute to Kevin Raerty, 1968 - 2024Pictured: Kevin Raerty (Right) receiving a fellowship by the Royal Society of Chemistry for his dedicaon and outstanding contribuon within the chemical sciences industry.

BASA Bullen Issue 10414Mapei – A focus on sustainabilityAs a result of our commitment to reduce our impact on the planet, we have a new section dedicated to Sustainability on our website. http://sustainability.mapei.it/Mapei (UK) is thrilled to announce a significant step forward in our commitment to sustainability and environmental stewardship. In alignment with our ongoing efforts to integrate sustainable practices across all operations, we are looking to appoint a new Sustainability Officer. This strategic addition to our team underlines our dedication to not only meeting but exceeding their sustainability goals. In this role, our Sustainability Officer will be responsible for developing and implementing our sustainability strategy, ensuring that we adhere to the highest environmental standards. This will include oversight of our efforts to reduce carbon emissions, enhance energy efficiency, and promote sustainable resource use throughout our operations. They will also play a crucial role in engaging with stakeholders, including corporate departments, employees, customers, and suppliers, to foster a culture of sustainability within and beyond our company.Phil Breakspear (Managing Director), expressed excitement about the appointment, stating, "Bringing a Sustainability Officer on board is a pivotal moment for Mapei (UK). The expertise and passion for sustainability will be instrumental in driving our efforts forward. This new appointment will not only reflect our commitment to environmental responsibility but also our belief in the importance of sustainability as a cornerstone of our business strategy."Contact Paul Hodgetts for more information. p.hodgetts@mapei.co.uk. This confirms the investment by the Mapei Group into the UK market after the announcement last year about the acquisition of a second sight in the Northwest to provide a new manufacturing facility for Mapei admixtures. We look forward to featuring the opening of the new facility in the next issue of the BASA Bulletin.Chemique Adhesives, a leading UK manufacturer of industrial adhesives has recently announced the unveiling of its revamped company logo. This strategic redesign marks a signicant milestone in the company's growth, adapng a fresh, modern look.Since its establishment in 1985, the company has witnessed many changes including a recent expansion, driven by sustained growth. The updated logo represents the current identy of the company and stands as a visual testament to its future aspiraons.“Recognising the need for change, we felt it was the ideal me to evaluate our company logo and introduce modern components to its design,” commented Jennie Mayou, markeng manager at Chemique Adhesives & Sealants Ltd. “Whilst we have embraced a more contemporary look, the new logo also retains elements that pay tribute to the company’s legacy and longstanding commitment to producing quality adhesives for nearly four decades.”The rebranding iniave also reects the recent changes made to the company’s re-designed website which oers visitors an enhanced design, simplied navigaon, and an improved user experience, showcasing their extensive product range.Stuart Francis, managing director at Chemique Adhesives & Sealants Ltd commented “We are thrilled to unveil our updated logo that demonstrates our commitment to adaptability and growth. This design not only reects our dedicaon to delivering exceponal products but also signies our vision for a dynamic and successful future. We are condent that the new logo will resonate with our valued customers and aract new audiences, strengthening our presence in the market.”www.chemiqueadhesives.comChemique Adhesives unveils new updated logo

For all your UK and EU REACH, CLP and BPR needsHelpdesk Our experts answer your REACH, CLP and BPR queries via email or telephoneConsultancy Support at any stage of the compliance process – a service tailored to your needsTraining Providing training through a wide range of public workshops, bespoke training and consultancy servicesMatchmaker Finding you trusted service providers to help you comply with REACH, CLP and the BPRA wholly-owned subsidiary of the Chemical Industries Association, REACHReady offers a condential, cost-effective service providing you with information and guidance on what you need to do to comply with UK and EU REACH, CLP and the Biocidal Products Regulation.With a current global membership of over 6,500 subscribers, we support people working at all stages of the supply chain and in a diverse range of industry sectors. Discover how we can help you – nd us online, email enquiries@reachready.co.uk or phone 020 7901 1444 today!REACHReady Gold Membership gives you:• Access to a specialist-staffedHelpdesk• Up to an hour of freeconsultancy for newsubscribers• 20% discount on publicseminars, training andworkshops… and morewww.cia.org.uk/reachreadyContact your Trade Association or REACHReady to apply for your REACHReady Gold membership at a 25% discounted rate!

Your Member BenetsAnity PartnersOur aliaon oers members access to the Construcon Products Associaon guidancenotes and research and the FEICA extranet. We also work closely with BSI, ACA, BCF, ASA, TWI, SAA & TTA on a number of topics.Online SupportWe run a free 30-minute virtual drop-in session to present important regulatory, and business informaon and general guidance for members every Friday at 10am.Trade Associaon DirectoryFree lisng in the BASA Handbook, distributed at the CHEMUK exhibion and promoted on our socials, as well as an online directory on the BASA website. We also encourage members to send in their company news to publish in the BASA Bullen and on our social plaorms.Events and NetworkingWe run events for members throughout the year including; the AGM, Business Forum & Industry Lunch, Sports Day & a new BASA Awards Night. We also hold free Technical Forums online.HR, Legal, Health & Safety, Tax & VatAccess to ve business advice lines and over 750 free downloadable business documents from our partner Quest included in your membership fee. Plus a free, no obligaon, One 2 One review with a Quest Business Manager for every member.£Member OersOers from OAMPS Hazardous Industries, 4Ward Tesng Services, Equals Money Currency Exchange Services & Wallace Hind Recruitment. Discounts on ReachReady Gold Membership, FEICA conferences and key market reports with free aendence at selected FEICA seminars.BRITISH ADHESIVES & SEALANTS ASSOCIATION