Global Regulatory Update for July 2023

WEBINAR — Product Stewardship Practices For Effective Supply Chain Interaction, August 1, 2023, 11:00 a.m. – 12:00 p.m. (EDT), Via Webinar: International compliance in today’s evolving regulatory arena presents challenges to organizations. This webinar, presented by Catherine M. Croke, DBA, Director of Product Stewardship and Regulatory Affairs, The Acta Group (Acta^®); Lee A. Bowers, Vice President, Environmental Health & Safety, RPM International Inc. (RPM); and Michael J. Ford, President, Tradebridge Consulting, will explore current and proposed international regulations and restrictions in developed and emerging legislation and provide examples informing and proactively promoting product stewardship practices and regulatory compliance in supply chains. Register now.

AUSTRALIA

SWA Seeks Information On The Use And Regulation Of Non-Threshold Genotoxic Carcinogens: On June 9, 2023, Safe Work Australia (SWA) announced that it seeks to understand whether non-threshold genotoxic carcinogens (NTGC) are present in Australian workplaces, in what quantities, and for what purpose. According to SWA, its review of the Workplace exposure standards for airborne contaminants identified 33 chemicals as NTGCs with evidence of use in Australian workplaces. SWA would like to hear from stakeholders to learn:

• Which NTGCs are used in Australian workplaces;
   
• The quantity of each NTGC in the workplace;
   
• How they are currently used, including the industries and processes; and
   
• The control measures currently in place to minimize the risks to workers from exposure to NTGCs.

SWA seeks further information from stakeholders to inform decisions around how NTGCs should be regulated to protect workers from exposure to these carcinogens. SWA also seeks stakeholder feedback on the current regulatory requirements in place under the model work health and safety (WHS) laws to protect workers from exposure to carcinogens in Australian workplaces. Responses are due September 8, 2023.

BRAZIL

ABNT Updates Standard, Implementing GHS 7: The Brazilian Association of Technical Standards (ABNT) has adopted an amendment to the standard for classifying and labeling chemicals according to NBR 14725. The “new” NBR 14725:2023 merges the four-part standard into one and adopts the seventh revised edition of the United Nations (UN) Globally Harmonized System of Classification and Labeling of Chemicals (GHS). These revisions enter into force on July 4, 2025. More information will be available in a forthcoming memorandum.

CANADA

Canada Publishes Papers On Federal Plastics Registry And Recycled Content And Labeling Rules For Plastics: In April 2023, Canada released two papers for a 30-day comment period:

• Technical paper: Federal Plastics Registry: The paper outlines the technical details and reporting requirements being considered for the Federal Plastics Registry. Canada notes it has taken into account the significant feedback received from partners, stakeholders, and the public during consultations. A draft Section 46 notice under the Canadian Environmental Protection Act, 1999 (CEPA) is targeted for publication in the Canada Gazette, Part I, before the end of 2023, which will be followed by a further consultation period before the instrument is prepared in final; and
   
• Recycled content and labelling rules for plastics: Regulatory Framework Paper: The paper outlines a regulatory framework for plastic packaging and certain single-use plastics that includes recycled content requirements and labeling rules for recyclability and compostability. Canada intends it to provide an updated and more detailed overview of the regulatory approach it is proposing for the draft regulations currently under development. Canada has taken into account the significant feedback received from partners, stakeholders, and the public during consultations on these proposed rules and requirements. The draft regulations are targeted for publication in the Canada Gazette, Part I, before the end of 2023, which will be followed by a further consultation period before the final regulations are issued.

Canada Publishes Notice Of Intent To Address 65 Existing Substances Identified As CMP Priorities: On April 22, 2023, Canada published in the Canada Gazette a notice of its intent to address 65 existing substances identified as Chemicals Management Plan (CMP) priorities following categorization and other prioritization mechanisms. Canada placed the 65 existing substances into two categories to be addressed:

Category 1: Substances that need further data collection or will be considered as part of an expanded group that is not yet ready for assessment.

Category 2: Substances that will be addressed using alternative assessment strategies.

The notice states that pursuant to CEPA Section 70, should individuals have data or information that reasonably supports the conclusion that any of the above substances is toxic or is capable of becoming toxic, they are required to submit it to the Minister of Environment, unless they have knowledge that either the Minister of Environment or the Minister of Health already has the information.

Canada Holds Public Consultation On Draft State Of PFAS Report, Proposes To Recommend Adding PFAS To CEPA Schedule 1: On May 20, 2023, Canada published a Canada Gazette notice announcing the availability of its Draft State of Per- and Polyfluoroalkyl Substances (PFAS) Report (Draft Report). Canada proposes to conclude that the class of per- and polyfluoroalkyl substances (PFAS) meets one or more criteria set out in CEPA Section 64. According to the notice, the Minister of the Environment and the Minister of Health (the ministers) propose to recommend that the class of PFAS be added to the CEPA Schedule 1 List of Toxic Substances. The Draft Report provides a qualitative assessment of the fate, sources, occurrence, and potential impacts of PFAS on the environment and human health to inform decision-making on PFAS in Canada. The ministers have released a risk management scope document for PFAS to initiate discussions with stakeholders on the development of risk management options. Comments on the Draft Report and risk management scope document were due July 19, 2023. According to the Environment and Climate Change Canada (ECCC), understanding the importance of stakeholder engagement, it will accept late submissions. For late submissions, the program may focus on addressing comments that have an impact on the conclusion of the Draft Report, however. Should the proposed conclusion of the Draft Report be confirmed in the final report, there will be additional opportunities to engage and provide comments on potential risk management. Consultations will continue throughout risk management tool development, implementation, and publication. More information is available in our May 25, 2023, memorandum.

Bill To Modernize CEPA Receives Royal Assent: On June 14, 2023, ECCC announced that Bill S-5, Strengthening Environmental Protection for a Healthier Canada Act, received Royal Assent. ECCC states that “[t]his is a landmark step in keeping the environment and Canadians safe and healthy.” The bill amends CEPA to:

• Protect better vulnerable populations who are most impacted by pollution;
   
• Advance Indigenous reconciliation by confirming the implementation of the United Nations Declaration on the Rights of Indigenous Peoples, including free, prior, and informed consent, and the role of Indigenous knowledge in decision-making related to the protection of the environment and human health, and by adding new reporting requirements;
   
• Require a new Plan of Chemicals Management Priorities, increase the assessment of cumulative effects of exposure to multiple chemicals, and develop a Watch List to support the shift to safer chemicals;
   
• Promote the development and implementation of scientifically justified alternative testing methods and strategies to reduce reliance on vertebrate animal testing; and
   
• Incorporate an environmental purpose into the Food and Drugs Act so that environmental risks resulting from drugs can be managed and so that a modernized environmental regulatory framework for drugs can be developed under the Food and Drugs Act.

More information is available in our June 23, 2023, memorandum.

Canada Calls For Information On Certain Substances Under The CMP: Canada published a notice in the Canada Gazette on June 24, 2023, announcing that it is collecting information on 850 substances for the purpose of prioritization, risk assessment, and risk management. Canada is gathering information from Canadian manufacturers, importers, and users on the commercial status, facility information (for example, releases), and uses of these substances in Canada, pursuant to CEPA Section 71. According to the notice, the Minister of the Environment requires the information to assess whether the listed substances are toxic or are capable of becoming toxic, or to assess whether to control, or the manner in which to control the listed substances. The persons described in the notice must provide the specified information that may be in their possession, or to which they would reasonably be expected to have access. Responses are due January 17, 2024. More information will be available in a forthcoming memorandum.

HC Proposes To Introduce New Requirements For Consumer Chemical Products Under CCPSA: Health Canada (HC) has published a Notice of Intent to inform interested parties that it is seeking comment on a proposed regulatory initiative that would introduce requirements for certain human health hazards of concern (HHHOC) in consumer chemical products under the Canada Consumer Product Safety Act (CCPSA). HC proposes to introduce the following requirements for consumer chemical products under the CCPSA:

• Classification criteria for HHHOCs based on those set out in the GHS;
   
• Information disclosure requirements for HHHOCs based on GHS label elements, including hazard symbols, signal words (i.e., “Danger” or “Warning”), hazard statements (e.g., “May cause cancer”), precautionary statements (e.g., instructions for safe use and first aid), and ingredient disclosure requirements; and
   
• Additional protections, such as prohibitions, restrictions, or child-resistant container requirements, where deemed necessary.

HC notes that under this regulatory proposal, existing requirements of the Consumer Chemicals and Containers Regulations, 2001 (CCCR, 2001), including its classification criteria, prohibitions, information disclosure requirements, and container requirements, would remain in force. More information will be available in a forthcoming memorandum.

EUROPEAN UNION (EU)

EC Implements New Hazard Classes To CLP: On April 20, 2023, the European Chemicals Agency (ECHA) announced the implementation dates for the introduction of new hazard classes as part of the European Commission’s (EC) revision to Regulation (EC) No 1272/2008 on the Classification, Labelling, and Packaging of Substances and Mixtures (CLP). The new hazard classes and criteria rules will be phased in over several years. New substances must comply by May 1, 2025, and new mixtures by May 1, 2026. Substances placed on the market before May 1, 2025, must comply by November 1, 2026, and existing mixtures placed on the market before May 1, 2026, must comply by May 1, 2028.

The changes include new hazard classes for:

• Endocrine disruption for human health (ED HH) in Category 1 and Category 2;
   
• Endocrine disruption for the environment (ED ENV) in Category 1 and Category 2;
   
• Persistent, bioaccumulative, toxic (PBT), very persistent, very bioaccumulative (vPvB); and
   
• Persistent, mobile, toxic (PMT), very persistent, very mobile (vPvM).

More information is available in our May 9, 2023, memorandum.

EC Proposes Revised Regulation On Detergents: The EC announced on April 28, 2023, that it proposed a revised Regulation on detergents that would simplify and future-proof the current rules to protect better health and the environment, as well as ensure the better functioning of the Single Market for detergents. The press release notes that the revised rules would cover new innovative products like detergents containing micro-organisms and sustainable new practices like the refill sale of detergents. The new rules also introduce a digital labeling and a product passport for detergents and surfactants. The EC’s proposal is now subject to the approval of the European Parliament (EP) and Council as part of the ordinary legislative procedure.

ECHA Calls For Evidence On Analytical Methods To Measure CMR Substances In Childcare Articles: ECHA held a call for evidence on analytical methods to measure carcinogenic, mutagenic, or reprotoxic substances (CMR) in childcare articles. ECHA states that the EC has requested that ECHA prepare a report on CMRs in childcare articles. According to ECHA, this work will support the EC in the preparation of a restriction proposal for CMR 1A or 1B substances in childcare articles on the basis of Article 68(2) of the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) regulation. Responses were due June 7, 2023. More information is available in our May 16, 2023, blog item.

ECHA Publishes Q&A Documents Following The April 5, 2023, PFAS Restriction Proposal Online Information Session: ECHA published on May 3, 2023, and June 28, 2023, Question and Answer (Q&A) documents following the April 5, 2023, online information session on the proposal to restrict more than 10,000 PFAS under REACH. The proposal suggests two restriction options — a full ban and a ban with use-specific derogations — to address the identified risks. The first Q&A document focuses on questions regarding the consultation, opinion-making, and the restriction process. The second Q&A document provides answers from the five national authorities to questions concerning the content of the proposed restriction. More information is available in our May 4, 2023, blog item.

EP Approves Proposed Legislation That Would Prevent Greenwashing: The EP announced on May 11, 2023, that it approved the proposal for a new directive intended to help consumers make environmentally friendly choices and encourage companies to offer them more durable and sustainable products. The EP’s approved negotiating mandate foresees banning the use of general environmental claims like “environmentally friendly,” “natural,” “biodegradable,” “climate neutral,” or “eco” if these do not come with detailed evidence. The press release states that other misleading practices such as making claims about the whole product if the claim is true only for one part of it, or saying that a product will last a certain amount of time or can be used at a certain level of intensity if that is not true, will also be forbidden. According to the press release, to make products last longer, EP wants to ban the introduction of design features that limit a product’s life or lead to goods malfunctioning prematurely. The press release notes that additionally, producers should not be allowed to limit a product’s functionality when it is used with consumables, spare parts, or accessories made by other companies. The Council of the EU adopted its negotiating mandate on May 3, 2023. The press release notes that this means that negotiations between EP and the Council on the final content and wording of the directive can start “soon.”

ECHA Publishes Annual Report On Helpdesk Activities: ECHA has published its annual report on helpdesk activities. According to the annual report, in 2022, the national helpdesks (NHD) replied to almost 43,000 enquiries, and the ECHA Helpdesk to almost 9,500 questions. The annual report states that responses provided through the survey reflect the activities of the Biocidal Products Regulation (BPR), CLP, and REACH helpdesks across 34 countries. Helpdesks of three candidate and one third country also reported on their 2022 activities. More information is available in our May 26, 2023, blog item.

European Ombudsman Opens Investigation Into Risk Management Of Dangerous Chemical Substances By EC: The European Ombudsman opened an investigation on June 8, 2023, into the risk management role of the EC regarding dangerous chemical substances in the EU and the time taken to place substances on the authorization list and introduce restrictions to mitigate risks. Under REACH, the EC is responsible for adopting measures that subject the use of certain dangerous chemical substances to prior authorization or restrictions based on opinions or recommendations by ECHA and following consultation with representatives of EU member state governments, as part of the comitology process. As a first step, the Ombudsman states that it “set out a series of questions to the Commission aimed at determining the extent of and reasons for delays.”

ECHA Adds Two Chemicals To Candidate List Of SVHCs: ECHA announced on June 14, 2023, that it has added two new chemicals to the Candidate List of substances of very high concern (SVHC). One is toxic for reproduction, and the other has vPvB hazardous properties. According to ECHA, their uses include in inks and toners and in the production of plastic products. ECHA provides the following information regarding the chemicals:

According to ECHA, the Candidate List now has 235 entries, although some are groups of chemicals, so the overall number of impacted chemicals is higher. ECHA may place these substances on the Authorisation List in the future. If a substance is on that list, its use will be prohibited unless companies apply for authorization and the EC authorizes them to continue its use. More information is available in our June 16, 2023, blog item.

ECHA Accepting Comment On Draft SEAC Opinion On Proposed MCCP Restriction Proposal: ECHA is seeking comment on the draft opinion of its Committee for Socio-Economic Analysis (SEAC) concerning the restriction proposal for medium-chain chlorinated paraffins (MCCP) and other substances that contain chloroalkanes with carbon chain lengths within the range of C14 to C17. According to the Information Note on SEAC’s draft opinion, substances containing chloroalkanes with carbon chain lengths from C14 to C17 are used in various sectors and in a broad range of applications, such as polyvinyl chloride (PVC), adhesives and sealants, rubber, metalworking fluids, paints, and coatings. The Information Note states that they are mainly used as plasticizers, flame retardants, or extreme pressure additives. Comments on SEAC’s draft opinion are due August 14, 2023. Comments received will be taken into account before the adoption of the SEAC final opinion in September 2023. ECHA will send the Committee for Risk Assessment (RAC) and SEAC final opinions to the EC, which will make the decision whether to include the proposed restriction in REACH Annex XVII.

Council Of The EU Adopts New Regulation On Batteries And Waste Batteries: The Council of the EU announced on July 10, 2023, that it adopted a new regulation that strengthens sustainability rules for batteries and waste batteries. According to the press release, the regulation will regulate the entire life cycle of batteries — from production to reuse and recycling — and ensure that they are safe, sustainable, and competitive. The regulation will apply to all batteries, including all waste portable batteries; electric vehicle batteries; industrial batteries; starting, lightning, and ignition (SLI) batteries (used mostly for vehicles and machinery); and batteries for light means of transport (e.g., electric bikes, e-mopeds, e-scooters). The regulation sets targets for producers to collect waste portable batteries (63 percent by the end of 2027 and 73 percent by the end of 2030), and introduces a dedicated collection objective for waste batteries for light means of transport (51 percent by the end of 2028 and 61 percent by the end of 2031). The press release states that the regulation provides that by 2027 portable batteries incorporated into appliances should be removable and replaceable by the end-user, “leaving sufficient time for operators to adapt the design of their products to this requirement.” The regulation introduces labeling and information requirements on the battery’s components and recycled content. To give EU member states and economic actors on the market enough time to prepare, labeling requirements will apply by 2026. The regulation will be signed by the Council and the EP. It will then be published in the Official Journal of the European Union and enter into force 20 days after.

EC Calls For Transition Initiatives To Achieve Green And Digital Transition For The Chemical Industry: The EC announced on July 12, 2023, that it launched a call for transition initiatives to achieve the green and digital transition of the EU chemical industry. According to the EC, “[t]his call is key to working together with stakeholders to co-implement the actions highlighted in the Transition Pathway for the Chemical Industry.” The EC states that these actions “aim to strengthen the EU chemical industry’s competitiveness, reduce its vulnerability to a changing geopolitical landscape while supporting investments in safe and sustainable chemicals.” The EC invites all organizations, from small- and medium-sized enterprises (SME) to larger companies, public administration, civil society groups, and other interested parties, to participate. The call will provide businesses and organizations with the opportunity “to showcase what they are doing and intend to do for a climate friendlier, greener, and more digital chemical industry, such as projects on green tech solutions” and reducing carbon dioxide emissions. Once collected, the EC will publish the transition initiatives online to promote knowledge and synergies among different stakeholders and their activities. Moreover, according to the EC, the collection of transition initiatives will help identify the main gaps and inspire further actions to accelerate the transformation of the EU chemical industry towards a climate neutral future.

EC Restricts Exposure To Formaldehyde In Consumer Products: The EC announced on July 14, 2023, new rules establishing an emission limit of 0.062 milligrams per cubic meter (mg/m³) of formaldehyde into indoor air for the largest contributors, such as wood-based articles and furniture and to the interior of road vehicles. A limit of 0.08 mg/m³ will apply to all other articles such as textile, leather, plastic, construction materials, or electronic products. The EC states that producers of articles using formaldehyde will have 36 months to comply with the new rules, “providing sufficient time for stakeholders to implement the restriction requirements, develop relevant analytical methods to test formaldehyde emissions and deploy formaldehyde-free or low emitting formaldehyde products.” A 48-month limit will apply to vehicles. The EC notes that ECHA, with the support of industry and experts, will develop guidance facilitating harmonized implementation of the test conditions for the measurement of the formaldehyde emissions.

UNITED KINGDOM (UK)

UK Calls For Evidence To Support RMOA For Formaldehyde And Formaldehyde Releasers: The United Kingdom’s (UK) Health and Safety Executive (HSE) issued a call for evidence on April 26, 2023, to gather information and evidence that will support HSE and the UK Health and Security Agency (UKHSA) with the preparation of a regulatory management options analysis (RMOA) that examines exposure of the general public to formaldehyde from formaldehyde releasers in articles. HSE states that it is “interested in all aspects of the manufacture, import and use of articles that have the potential to release formaldehyde to indoor air during their service life, the rate of emissions of formaldehyde from these articles and actions that may be taken to reduce exposure to formaldehyde from these sources.” HSE is also interested in any product-specific legislation and standards that apply to these articles, as well as industry initiatives to reduce the potential for formaldehyde to be released from these articles. In addition to articles that have the potential to release formaldehyde, HSE notes that it is interested to understand the levels of formaldehyde that can be generated in indoor settings from processes that can release formaldehyde, including cooking, use of candles, and indoor domestic combustion, such as woodburning stoves and ethanol fires. The call for evidence closed June 25, 2023. More information is available in our May 22, 2023, memorandum.

HSE Proposes To Include Substances In UK REACH Substance Evaluation Rolling Action Plan: HSE has proposed to include three substances in the rolling action plan (RAP) for 2023 to 2025. HSE states that it has “sought to complement rather than replicate evaluation work that has been or will be performed by other regulatory regimes” (such as via EU REACH). According to HSE, its intention is to increase its overall understanding of the hazard and risk profile of the priority substances and their relevance to Great Britain (GB). HSE selects substances for inclusion in the RAP based on the hazard profile of substances and their exposure potential, including the quantities that are supplied. HSE identified one substance for evaluation in 2023. In 2024/25, HSE will focus on PFAS and consider recommendations from broader scoping activities, RMOAs, and the Environment Agency’s updated report on flame retardants when published.

More information is available in our June 6, 2023, blog item.

HSE Recommends Restricting Hazardous Substances In Tattoo And Permanent Makeup Inks: HSE announced on June 8, 2023, that it is recommending the restriction of hazardous substances in ink used for tattooing and permanent makeup (PMU) in GB. HSE states that the proposed restriction would target substances classified for carcinogenicity, mutagenicity, reproductive toxicity, skin sensitization, skin corrosion, and serious eye damage. HSE proposes concentration limits of substances in tattoo ink and PMU based on those established in the GB CLP Regulation: a concentration limit of 0.1 percent for substances that are prohibited for use in cosmetics because they are listed in Annex II or Annex VI of the Cosmetic Products Regulation (CPR). HSE proposes a derogation for 19 pigments (including Pigment Blue 15:3 and Pigment Green 7) that are prohibited for use in hair dyes but permitted for use in other types of cosmetics (such as lipsticks). According to HSE, its review of the available hazard information for these 19 pigments did not identify evidence indicating they are unsafe if used in tattoo or PMU ink. More information is available in our June 12, 2023, blog item.

UK REACH Amended To Extend Registration Deadlines: On June 28, 2023, Rebecca Pow, Parliamentary Under Secretary of State, Department for Environment, Food and Rural Affairs (Defra), signed the REACH (Amendment) Regulations 2023. The legislation amends the current UK REACH information submission deadlines by three years to:

• October 27, 2026, for substances included on the candidate list on or before December 31, 2023; substances that are CMR and manufactured or imported in quantities of one metric ton a year or more; substances that are very toxic to aquatic life and manufactured or imported in quantities of 100 metric tons or more a year; and all substances manufactured or imported in quantities of 1,000 metric tons or more a year;
   
• October 27, 2028, for substances added to the UK REACH candidate list before the above submission deadline; and all substances manufactured or imported in quantities of 100 metric tons or more a year; and
   
• October 27, 2030, for all substances manufactured or imported in quantities of one metric ton or more a year.

The legislation also amends the dates by which HSE must carry out 20 percent of compliance checks to October 27, 2027, October 27, 2030, and October 27, 2035. More information is available in our July 12, 2023, blog item.

Defra Reviews Specific Aspects Of UK REACH: UK REACH Article 138 places a duty on the Secretary of State to carry out three reviews of specific aspects of UK REACH. These reviews examined:

• Whether to extend the requirement to complete Chemical Safety Assessments (CSA) and Chemical Safety Reports (CSR) to registrants who produce substances in quantities of less than ten metric tons a year: According to Defra’s report, the current review of UK REACH registration through the REACH Alternative Transitional Registration model may result in changes in information requirements. Defra states that it “would not be appropriate to draw conclusions independently of that wider development work and, therefore, we do not propose any amendments to requirements for CSAs in CMR registrations in the 1 to 10 tonnage band at this time.”
   
• The scope of Article 33 where suppliers must provide, and consumers may demand, information about SVHCs in articles (as defined in the Review of Article 33): Defra states in its report that before considering whether to extend the scope of Article 33, further work would be needed to gather a stronger evidence base from suppliers with wider consultation with suppliers and other stakeholders to inform any decision. According to Defra, consideration would need to address the balance between the business benefits, the objectives of UK REACH for protection of human health and the environment, and the burden of information transfer duties on suppliers.
   
• The standard testing requirements for reproductive toxicity at lower tonnages: According to Defra’s report, Defra has contributed to national and international activities to support the development and evaluation of non-animal test methods and new approach methodologies (NAM).

UK REACH Article 117(4) places a duty on the Secretary of State, in co-operation with the devolved administrations, to publish a general report every five years on:

• The experience acquired in the operation of UK REACH; and
   
• The amount and distribution of funding made available by Defra for the development and evaluation of alternative test methods.

This report is the first exercise of this duty. In carrying it out, Defra considered the experiences of government, regulators, and stakeholders. The overarching aim of the evaluation was to start to answer the following questions about UK REACH:

• Process: To what extent is Defra and its delivery agencies providing an effective operational service?
   
• Impact: What are the costs and benefits of UK REACH?
   
•  Value for Money: To what extent is UK REACH providing good value for money?

Defra notes that the evaluation was undertaken at an early stage of UK REACH implementation and that as such, limited information was available to answer these questions. Defra expects evaluations to be carried out in the medium and long term to provide more complete answers. According to Defra, one of the main objectives at this stage was to identify learning points to help inform the future implementation of UK REACH and to lay the foundations for subsequent evaluation stages.

HSE Contact Information For Various PPP Functions Is Changing: A number of HSE e-mail addresses relating to the regulation of pesticides are changing because the technology supporting these functions is no longer supported. According to HSE, it will continue to monitor the old e-mail addresses until August 1, 2023, at which point they will no longer be available. HSE notes that no automatic forwarding to the new mailboxes is possible.

• Old e-mail address: Applications@hse.gov.uk
   
• New e-mail address: PPPapplications@hse.gov.uk
  
   
• Old e-mail address: CRDinformationmanagement@hse.gov.uk
   
• New e-mail address: PPPenquiries@hse.gov.uk
  
   
• Old e-mail address: AerialSprayingPermits@hse.gov.uk
   
• New e-mail address: PPPAerialSprayingPermits@hse.gov.uk
  
   
• Old e-mail address: E-Approvals@hse.gov.uk
   
• New e-mail address: PPPE-Approvals@hse.gov.uk

For certificates of Freesale:

• Old e-mail address: asg@hse.gov.uk
   
• Old e-mail address: parm@hse.gov.uk
   
• New (consolidated) e-mail address: PPPenquiries@hse.gov.uk