REACH, Product Safety & Consumer Well-being

Product Safety and Consumer Well-being

To understand and manage the potential health, safety, and environmental risks of our products, we take a careful and considered approach to risk evaluation and assessment. Our corporate regulatory team works with stakeholders, customers and suppliers to monitor and react to changes in hazard properties or exposure of our products. Through careful product stewardship, we aim to deliver innovative and sustainable products with increased performance and value, without harming people or the environment.

Our team of experts

The regulatory team is comprised of a global network of highly effective individuals with a wide variety of expertise, including regulatory affairs professionals, toxicologists, ecotoxicologists and hazard communication specialists.

In addition to supporting our core business units, many of our corporate regulatory team members work collaboratively with a wide range of external industry bodies and research groups, helping to enhance and improve the safety of our products and the global regulations that govern their use. Our active participation in research groups, trade associations and national and international committees allows for a mutual exchange of information, befitting Innospec, our counterparts and customers.

We are proud to work with:

  • ACC (American Chemistry Council)
  • CIA (UK’s Chemical Industries Association)
  • CEFIC (European Chemical Industry Council)
  • ATC (Technical Committee of Petroleum Additive Manufacturers in Europe)
  • CESIO (European Committee of Organic Surfactants and their Intermediates) and ERASM (Environmental and Health Risk Assessment Management of Surfactants and Detergents)
  • CTPA (Cosmetic, Toiletry and Perfumery Association) and EFfCI (European Federation for Cosmetic Ingredient Manufacturers)
  • EOSCA (European Oilfield Specialty Chemicals Association)

Global Chemical Regulations

National and regional regulations are continuously evolving and we work hard to ensure that our products comply with changes in legislation. 

In 2023, the European Commission took further steps to implement their flagship Chemicals Strategy for Sustainability (CSS) project – part of the wider European Green Deal.

Key actions included:

  • Public consultations and workshops on the outlined concepts and proposals
  • A proposal for the revision of the REACH Regulation
  • A roadmap setting for EU REACH restrictions and recommendations on the European assessment framework for ‘Safe and Sustainable by Design’

On 31st March 2023 the European Commission published a Delegated Act on the Classification and Labelling of chemicals, which included new hazard classed for chemicals, for example which have endocrine disrupting (ED) properties.

Our team of experts actively monitors and evaluates regulatory developments as part of our proactive approach to address how potential changes in legislation impact on our products and how our customers use them.

Staying Compliant with REACH

  • Turkish and Korean REACH
To ensure compliance with current EU REACH regulations, we regularly submit new registrations for substances newly introduced to the market. Furthermore, we to continue to update registration dossiers with new and updated information when requested by ECHA.

It is also a legal requirement to pro-actively review and update registration dossiers with the latest information and assess any impact this has on workers, consumers, and environmental safety. We continue with our ongoing commitment as a signatory member company to the CEFIC Dossier Improvement Plan and remain on schedule to complete reviews and resubmissions of all registration dossiers by the 2026 target date and complete all our obligations under the Plan. In 2023, we updated 18 of our registration dossiers.
After Brexit, we actively participated in UK government consultations and workshops on future chemicals strategy and regulations. Following these consultations, the proposal is to extend the registration deadlines of UK REACH.

This change will coincide with an alternative registration model (ATR), proposed in response to stakeholder concerns regarding the cost of acquiring and submitting the required data to complete ‘grandfathered’ registrations. The model will aim to reduce costs to businesses of this transition, while also ensuring high levels of human health and environmental protection remain. UK Government proposals for the ATR are expected during 2024.

We have successfully completed the initial ‘grandfathering’ of our existing EU REACH registrations into UK REACH and any necessary downstream user import notifications (DUINs) to ensure our products remain compliant on the UK market. We also submit “New Registration, Existing Substance (NRES)” and new substance registrations under UK REACH when required. We await the outcome of the ATR proposals before making necessary preparations to complete any data submission requirements for the UK registration process of our “grandfathered”, DUIN and NRES substances.
Turkey and South Korea have introduced country-specific chemical management regimes similar to EU REACH with staged registration deadlines based on tonnage and hazard.

Although Turkey extended their registration deadlines late in 2023, thus removing the requirement for all substances to be registered by the end of 2023, our regulatory team completed the registration of 20 substances in 2023 falling under KKDIK. Work to advance further registrations under KKDIK will now progress in line with the revised deadlines.

The Regulatory Team are also undertaking registration of all applicable substances falling under the Korean REACH Program (K-REACH) with the next deadline being for the registration of substances over 100 tpa by the end of 2024.

Animal Testing

Compliance with regional and international regulations is non-negotiable and replying promptly and professionally to checks from the European Chemical Agency (ECHA) on our EU REACH registered substances is an integral part of our compliance commitment.

Unfortunately, many regulatory authorities still require animal testing to assess the (eco)toxicological properties of new and existing products. Innospec remains fully committed to eliminating or replacing using animal by employing suitable alternatives, when appropriate from both a scientific and legislative standpoint. As part of these efforts we work closely with industry groups, our registration partners, and contract research laboratories, on new approach methods (NAMs) to develop and deliver robust scientific strategies that minimizes (and ideally eliminates) vertebrate animal testing.

Minimizing animal testing

Throughout the course of 2023, we submitted EU REACH dossiers for several substances from our performance chemicals business, which incorporated NAM and Next Generation Risk Assessment (NGRA) approaches used to replace animal testing. We conservatively estimate that 15,000 animals have been spared as a result of the strategy we utilised for these substances. The dossiers are now under review at the European Chemicals Agency (ECHA).

As evidence of further commitment in this area, Innospec are also active members of the Animal-Free Safety Assessment (AFSA) and the International Collaboration on Cosmetics Safety (ICCS).

In 2023, we are proud to have collaborated with AFSA colleagues on a scientific publication which evaluated animal testing as a last resort under the EU REACH regulation. This publication highlighted some of the challenges and opportunities within this subject area and included a case study on one of our Innospec products. The paper should serve to stimulate dialogue with key stakeholders and catalyze the necessary changes to avoid using animals for testing under chemical regulations like EU REACH.

“It is great to work for a company that is committed to the use and deployment of novel non-animal testing approaches to ensure the safety of the chemical ingredients we manufacture. On both a personal and professional level, it was really satisfying to advance the science and challenge the status quo to avoid animal testing under the EU REACH regulation for some of these ingredients through extensive experimental testing and modelling programs throughout 2022. We collaborated closely with several critical partners to ensure the new data will be ready for submission to the European Chemicals Agency in 2023. Our team did a fantastic job, and we believe the initiative we have taken for just four of these ingredients could potentially spare approximately 10,000 animals from unnecessary testing to demonstrate safety and compliance with EU REACH.” James Dawick, Senior Toxicology and Risk Assessment Manager 

Product Stewardship

Our expert software system Intelligent Authoring® supplied by Sphera® supports our regulatory function underpinning our product stewardship. For example:

  • It facilitates the publishing of safety data sheets (SDS) in over 40 languages and generates labels for 5,000+ products
  • It is used to cross-check global chemical inventory compliance, such as the Toxic Substance Control Act (TSCA) in the US
  • Importantly, Intelligent Authoring® holds the physical chemical (eco) toxicology, environmental-fate and hazard classification data for over 20,000 individual substances that we continually use and/or monitor

The database enables us to classify our products correctly for human and environmental health and also provides the correct handling and use advice.

Our regulatory team are involved in the early stages of all new product research and development to provide support from first concept. We are committed to minimizing environmental impact through all stages of our product development.

Through careful product stewardship we aim to deliver innovative and sustainable products with increased performance and value, without harming people or the environment.