UK REACH: Post-Brexit Chemical Regulation and Compliance

The United Kingdom has notified the World Trade Organization (WTO) of a draft regulation proposing the addition of 30 substances to the GB Mandatory Classification and Labelling (GB MCL) List. This is one of a series of ongoing updates to the UK’s independent chemicals framework following Brexit and is aligned with the GB Classification, Labelling and Packaging (CLP) Regulation, which applies in England, Scotland, and Wales.

The GB MCL list is updated regularly to reflect scientific developments and protect human health and the environment. This update marks another step in Great Britain’s regulatory divergence from the EU’s CLP system since the end of the Brexit transition period.

Key Substances and Hazards

The proposal covers substances posing serious risks to human health and the environment, including:

• Carcinogens: e.g. 1,4-dichloro-2-nitrobenzene (Carc. 1B)

• Reproductive toxins: e.g. sodium perborate and glycerol formal (Repr. 1B)

• Aquatic hazards: e.g. copper, pyraclostrobin

• Mutagens and sensitizers: e.g. N,N'-methylenediacrylamide (Muta. 1B), several fragrance substances (Skin Sens. 1)

• Other hazards, including causing serious eye damage, having specific target organ toxicity (STOT), and being flammable.

The classifications are based on scientific evaluations by the UK Health and Safety Executive (HSE).

Implications for Industry

Manufacturers, importers, and downstream users will be required to update hazard labelling and safety data sheets, and potentially reformulate products in order to comply with the proposed classifications.

Consultation Details

The proposal was notified to the World Trade Organization under reference G/TBT/N/GBR/101. Stakeholders are invited to submit comments on the draft regulation by 6 June 2025. The full text of the proposed measure, including the list of substances and their classifications, is available in the notified document, which can be accessed here.

On 10 April 2025, the Environmental Audit Committee (EAC) of the UK Parliament launched a new inquiry to investigate the environmental and health risks posed by per- and polyfluoroalkyl substances (PFAS), often referred to as “forever chemicals”. The inquiry will also assess the robustness of the UK’s current regulatory approach to managing these substances.

Why PFAS Are a Concern

PFAS are widely used in consumer products such as waterproof clothing, non-stick cookware, cosmetics, and food packaging due to their resistance to heat, water, and grease. However, these substances are highly persistent in the environment and in the human body. Scientific studies have linked PFAS exposure to:

• Reduced fertility and developmental issues.

• Certain cancers.

• Hormone disruption.

• Immune system suppression.

Their widespread use and long-lasting nature have led to growing public and political concern in the UK and around the world.

Objectives of the Inquiry

The EAC inquiry will examine:

• The extent and sources of PFAS contamination in the UK.

• The current capabilities of UK regulators to detect, monitor, and manage PFAS risks.

• The adequacy of existing laws and guidance on the manufacture, use, and disposal of PFAS.

• How the UK’s regulatory approach compares with that of other jurisdictions, particularly the EU and the US.

Call for Evidence: What Submissions Should Cover

The Committee invites written submissions from stakeholders, including scientists, regulators, industry representatives, environmental groups, and members of the public. Submissions may address:

• The extent of PFAS use in the UK and in specific sectors.

• Known or potential environmental and health impacts of PFAS.

• The effectiveness of the current UK regulatory controls (including REACH under UK law).

• Challenges in monitoring PFAS in the environment and in consumer products.

• The role of alternatives and opportunities for phase-out or substitution.

• International best practice that could inform UK regulation.

• Public awareness and risk communication of PFAS exposure.

Deadline for Submissions

Written submissions must be received by 17:00 BST on Monday, 26 May 2025. Full details and the submission portal are available on the UK Parliament website here.