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The UK Health and Safety Executive (HSE) has published its 2022 report on the official monitoring of plant protection products (PPPs), revealing significant compliance issues in the food and agriculture sectors. Issued under Article 68 of the retained EU Regulation 1107/2009, the report provides insights into national control measures for placing PPPs on the market and monitoring their use.

Summary of Official Controls and Enforcement

• 1,631 inspections were carried out by the HSE across Great Britain in 2022, targeting storage sites, online sales, and agricultural use.

• 65 product samples were collected for laboratory testing. Of these, 28 failed to meet legal requirements due to the presence of unauthorised co-formulants, unapproved use conditions, and labelling deficiencies.

• Follow-up actions included improvement notices, voluntary withdrawals, product recalls. In a few cases, there were enforcement notices and prosecutions.

• The focus of several campaigns was on high-risk products, such as triazole fungicides and copper compounds, and increased scrutiny of online marketplaces.

Residue Monitoring and Food Chain Risk

In collaboration with the Food Standards Agency (FSA), Food Standards Scotland (FSS), and DAERA in Northern Ireland, the UK’s pesticide residue surveillance programme tested 3,304 food samples across a wide range of commodities. Overall compliance with maximum residue levels (MRLs) was over 98%, but 60 samples exceeded the legal thresholds.

One area of concern was the detection of tri-allate residues in kale and broccoli, likely due to volatilisation and drift after application. Risk management discussions have been initiated with authorisation holders.

Northern Ireland: Online Sales and Compliance

The Department of Agriculture, Environment and Rural Affairs (DAERA) investigated six cases of non-compliance relating to unauthorised online pesticide sales. All cases were voluntarily resolved, underscoring the growing attention that enforcement is paying to digital platforms.

Industry Implications

The 2022 findings underscore the importance of:

• Maintaining robust supply chain controls to prevent contamination.

• Verifying authorisations for products marketed online and in stores.

• Ensuring that correct labelling and formulation details are upheld throughout the manufacturing and distribution process.

Looking Ahead

The HSE has indicated that future monitoring will continue to target high-risk products, unapproved imports, and digital sales channels. Retailers, manufacturers, and users of PPPs are encouraged to carefully review their compliance obligations.

Access the full 2022 report here.

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.