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The UK’s Health and Safety Executive (HSE) has launched an eight-week public consultation on proposed legislative reforms for chemicals regulation in Great Britain. The consultation, which runs until 18 August 2025, invites stakeholders to share their views on planned changes to the GB Biocidal Products Regulation (GB BPR), Classification, Labelling and Packaging (GB CLP), and Prior Informed Consent (GB PIC) regimes.

Supporting Economic Growth Through Regulatory Reform

The proposed reforms aim to streamline regulatory processes, reduce costs for businesses, and maintain high standards of health and environmental protection. This initiative is part of the UK Government’s broader Regulatory Action Plan (RAP), which aims to foster innovation and economic growth by modernising regulatory frameworks.

Key Proposals Covering Biocides, CLP and PIC

The consultation sets out targeted reforms for three key chemical regulatory regimes:

• Biocides (GB BPR):

  • Recognising international approvals: The HSE is proposing that biocidal active substances and products approved in trusted foreign jurisdictions to be recognised in Great Britain without the need for a full domestic evaluation. This would significantly reduce the time and cost of bringing products to the GB market while maintaining safety standards.

  • Replacing fixed approval dates with risk-based reviews: Instead of requiring periodic renewals, biocidal active substances and potentially products would remain approved indefinitely, unless ‘called in’ for review based on new evidence of potential risks.

  • Expanding essential use derogations: The reforms would enable temporary authorisations for biocidal products or substances that are essential to society, ensuring the continued availability of critical products while alternatives are sought.

  • Introducing powers for future updates: The HSE is seeking the authority to make technical and procedural changes to the GB BPR through secondary legislation, which would allow for greater flexibility and faster regulatory adjustments.

• Classification, Labelling and Packaging (GB CLP):

  • Introducing a fast-track classification process: A new, streamlined evaluation route is proposed for substances classified in countries that apply the UN GHS, with transparent processes. This would enable quicker updates to mandatory classifications, reducing regulatory delays.

  • Ending the GB CLP notification requirement: Businesses would no longer be required to notify the HSE when placing new substances on the GB market, easing administrative burdens without compromising safety oversight.

  • Relocating technical notes online: Explanatory notes linked to mandatory classifications would be moved from legislation to the HSE website, allowing for faster updates and simpler access for businesses.

  • Granting powers for general updates: The HSE is proposing new powers to ensure that GB CLP remains aligned with international developments and evolving scientific knowledge.

• Prior Informed Consent (GB PIC):

  • Removing outdated procedures: The consultation proposes eliminating the Special Reference Identification Number (SRIN) process for small-quantity exports used for research, as this is now considered unnecessary.

  • Simplifying the waiver process: The requirement for explicit consent from importing countries could be streamlined to allow for a more consistent application of waivers for eligible chemicals.

  • Ensuring timely updates: The HSE is also seeking powers to make future amendments to GB PIC more efficiently, thereby ensuring the UK can meet its international obligations without delay.

Improving Flexibility

The proposals are designed to give the HSE greater flexibility in decision-making, while ensuring that the UK remains responsive to international scientific developments and avoids unnecessary divergence from global standards. The reforms are also intended to protect the integrity of the UK internal market, including Northern Ireland.

How to Participate

Stakeholders, including manufacturers, importers, distributors, NGOs, and members of the public, are invited to submit their views here on the HSE consultation portal by 18 August 2025.

On 4 June 2025, the UK Government published an interim position statement detailing how the concepts of persistent, mobile and toxic (PMT), and very persistent and very mobile (vPvM) substances will be used to support risk management under UK REACH. This new approach aims to enhance the regulatory control of per- and polyfluoroalkyl substances (PFAS), as these substances pose significant environmental challenges due to their extreme persistence and mobility in the environment.

The interim position statement was published by the Department for Environment, Food & Rural Affairs (Defra) and applies to England, Scotland and Wales.  It marks a significant step in aligning UK chemical policy with emerging international practices. Although PMT and vPvM are not yet recognised as formal hazard classes under UK REACH or UK CLP, the government intends to leverage these concepts to support restriction proposals and risk management measures, particularly with regard to PFAS.

PFAS as a Regulatory Priority

PFAS are often referred to as “forever chemicals” due to their resistance to environmental breakdown and capacity to spread widely through water systems. UK environmental monitoring data has revealed widespread PFAS contamination in rivers, groundwater, and organisms, including fish, suggesting that their mobility and persistence result in diffuse and long-term pollution.

Due to these characteristics, PFAS do not easily fit into traditional risk assessment models that rely on thresholds or predicted no-effect concentrations. The government is therefore adopting a precautionary approach based on the PMT/vPvM concept to guide early regulatory intervention and prevent irreversible environmental harm.

Key Features of the Interim Approach

• Non-threshold regulatory principle: Rather than identifying safe exposure levels, the UK approach focuses on minimising emissions of PMT/vPvM substances throughout their lifecycle.

• Basis for restriction proposals: The interim concept will support the development of restriction dossiers under UK REACH, including the anticipated restriction on PFAS, by identifying substances of concern based on their PMT/vPvM properties.

• Use of Article 57(f): Substances identified as PMT or vPvM may be considered substances of very high concern (SVHCs) under UK REACH, using the provision for substances with equivalent levels of concern.

Next Steps and Broader Implications

While the interim approach currently targets PFAS, the government notes that the methodology may later be expanded to cover other PMT/vPvM substances. The Environment Agency has been tasked with advancing the scientific and technical tools needed to support this strategy, including:

• Improved methods for identifying mobility beyond traditional partition coefficients (e.g. Kₒc),

• Enhanced tools for screening and prioritising PMT/vPvM substances, and

• National monitoring programmes to track their presence in the environment.

In parallel, the UK will continue to engage with international forums, such as the UN Globally Harmonized System (GHS), and monitor developments in the EU’s Classification, Labelling and Packaging (CLP) Regulation, which recently introduced PMT/vPvM as new hazard classes.

A Step Toward Future Integration

Although PMT and vPvM are not yet part of the UK’s formal hazard classification system, this interim position enables the government to address substances with properties that pose serious long-term environmental risks. By incorporating the PMT/vPvM concept into restriction proposals, the UK intends to prevent irreversible contamination and enhance chemical safety in a scientifically robust and precautionary manner.

The full text of the interim position statement can be found here.