, "On November 4th, 2025, the UK Health & Safety Executive (HSE) has published its draft recommendation for 2025 titled "" HSE is collecting GB-specific information on 4,4'-bis(dimethylamino)-4''-(methylamino)trityl alcohol that contains ≥0.1% Michler’s ketone or Michler’s base, to help decide whether it should be included in Annex 14 of UK REACH.
The substance is an SVHC because the impurities Michler’s ketone and Michler’s base are both classified as Carcinogen 1B. The alcohol itself becomes carcinogenic if these impurities are present at ≥0.1%.
Key points:
Identity: EC 209-218-2; CAS 561-41-1; included in the UK Candidate List since 2021.
Use: Previously used as a dye, particularly in printing and writing inks, which may end up in printed articles.
Market volume:
No UK REACH registrations exist.
Only 3 DUINs, but with large uncertainty, so actual GB use is likely low or nonexistent.
Regulatory context:
The substance (with impurities) is already listed on Annex 14 of EU REACH.
No EU authorisation applications have been submitted, suggesting substitution or impurity levels below 0.1%.
Impurity-driven concern:
The regulatory issue arises from impurities, not the dye alcohol itself.
In many cases, the actual levels of Michler’s ketone/base may be far below 0.1%, reducing the relevance of authorisation.
HSE’s current view:
GB use likely mirrors the EU—minimal or substituted.
Adding the substance to Annex 14 might not be the most effective risk-management approach, but doing so would support regulatory consistency with the EU and reduce administrative burden for companies trading in both markets.
What HSE is seeking:
HSE requests further GB-specific information on:
Uses
Tonnages
Presence and levels of impurities
to refine their prioritisation assessment.
The Comments are Opened on 4 Nov 2025
Interested parties are invited to submit comments on this substance within 3 months of the publication date. Information submitted will be used to refine this assessment for consideration in future prioritisation work.
Comments closes on 4 Feb 2026"
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