The UK Health and Safety Executive (HSE) has published its annual UK REACH Article 83 Report (2023–2024) and Work Programme for 2024–2025, highlighting ongoing regulatory work and outlining upcoming priorities under the UK REACH framework.

PFAS and Lead Under Regulatory Focus

HSE continues to assess the risks of per- and polyfluoroalkyl substances (PFAS), with work ongoing to investigate their use as processing aids in the manufacture of fluoropolymers. In parallel, the Agency is preparing a restriction dossier on PFAS in firefighting foams, which is expected to be submitted for public consultation in 2024/25.

The HSE is also finalising its restriction opinion on lead in ammunition used in outdoor shooting, covering both human health and environmental risks. This follows a public consultation completed in 2023.

Upcoming Work in 2024–2025

The Work Programme outlines the continuation of nine Regulatory Management Options Analyses (RMOAs), including substances such as:

• Benzene-1,2,4-tricarboxylic acid 1,2-anhydride (trimellitic anhydride) – investigated for respiratory sensitisation risks.

• Bisphenol S (BPS) and Bisphenol F (BPF) – evaluated for endocrine disrupting properties.

• Octamethylcyclotetrasiloxane (D4) and Decamethylcyclopentasiloxane (D5) – investigated for persistence and potential environmental concerns.

No new RMOAs are planned for 2024/25.

Additionally, the HSE will assess up to six substances proposed as Substances of Very High Concern (SVHCs) under EU REACH for their relevance to the UK market. One such substance that has already been evaluated in 2023/24 was melamine, due to concerns over reproductive toxicity and widespread use.

Key Activities in 2023-2024

During 2023/24, the HSE:

• Processed all new UK REACH registrations and Article 26 inquiries within the statutory three-week timeframe.

• Carried out compliance checks on at least 20% of registration dossiers.

• Evaluated all submitted testing proposals to avoid unnecessary animal testing.

• Issued authorisation opinions on time, including assessments of trichloroethylene uses.

• Published the UK REACH evaluation report under Article 54 by the February 2024 deadline.

For 2024/25, the HSE will maintain these operational targets and continue to invest in IT systems and stakeholder engagement efforts to support future evaluations and restrictions.

The work programme was developed in collaboration with the Environment Agency and the Appropriate Authorities (Defra, the Scottish Government, and the Welsh Government) and reflects previously established regulatory priorities.

Access the full 2023-2024 Annual Report here and the 2024-2025 Work Programme here.

The United Kingdom and the European Union have launched public consultations on draft risk profiles for polybrominated dibenzo-p-dioxins and dibenzofurans (PBDD/Fs), including mixed polybrominated/chlorinated dibenzo-p-dioxins and dibenzofurans (PBCDD/Fs). These consultations are part of the process under the Stockholm Convention on Persistent Organic Pollutants (POPs) to evaluate and possibly regulate these substances due to their persistence in the environment and potential health risks.

Background on PBDD/Fs and PBCDD/Fs

PBDD/Fs and PBCDD/Fs are unintentional by-products of various industrial processes, including the combustion of materials containing brominated flame retardants and certain metallurgical processes. Due to their persistence in the environment and their potential to bioaccumulate, these substances are of concern for both the environment and human health.

UK Consultation Details

The UK Department for Environment, Food & Rural Affairs (DEFRA) has published a draft risk profile for PBDD/Fs and PBCDD/Fs and is inviting stakeholders to comment. The consultation period is open from 17 March to 19 May 2025. Stakeholders are encouraged to review the draft risk profile and provide feedback by email to POPs@defra.gov.uk within the specified timeframe.

EU Consultation Details

The European Chemicals Agency (ECHA) has also published a draft risk profile for the same group of substances and is seeking input from interested parties. The EU consultation is open until 20 May 2025 and comments can be submitted here.

Next Steps in the Stockholm Convention Process

Feedback from these consultations will contribute to discussions at the upcoming 20th meeting of the Stockholm Convention POPs Review Committee (POPRC-20), scheduled for 29 September to 3 October 2025. The Committee will review the draft risk profiles and stakeholder comments to determine the need for global regulatory actions on these substances.