UK Regulatory News

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 b...

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.

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 agricultu...

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...

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 (PF...

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.

On 10 March 2025, the UK Department for Environment, Food & Rural Affairs (DEFRA) launched two public consultations on proposed exemptions under the Restriction of the Use of Certain Hazardous Substan...

On 10 March 2025, the UK Department for Environment, Food & Rural Affairs (DEFRA) launched two public consultations on proposed exemptions under the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2012 (RoHS) in Great Britain (England, Scotland and Wales). Stakeholders are invited to submit comments by 4 May 2025.

About the RoHS Regulation

The RoHS Regulation restricts the use of certain hazardous substances in electrical and electronic equipment (EEE) placed on the market. Originally derived from EU legislation, it aims to reduce the environmental and health risks posed by substances such as lead, mercury, cadmium, and certain flame retardants.

Under the UK RoHS framework, industry can apply for exemptions to allow the use of restricted substances above the specified limits if certain criteria are met. Applications are assessed through a formal evaluation process and, if granted, exemptions apply to the whole - not just the applicant.

Consultation 1: Lead in Engine Control Units

The first consultation concerns a proposed renewal of an exemption allowing the use of lead in solder used in sensors, actuators, and engine control units (ECUs) for combustion engines. The applicant argues that no reliable alternatives are currently available for these components. If granted, the exemption would be valid until 1 January 2027 and would allow the introduction of approximately 0.123 kg of lead per year into the GB market. The consultation is available here.

Consultation 2: Mercury in Discharge Lamps

The second consultation concerns a request for an exemption for the use of mercury in certain discharge lamps designed for special purpose applications. Mercury is currently restricted under RoHS due to its toxicity, but exemptions may apply where no viable alternatives exist, particularly in specialised lighting systems. The consultation can be accessed here.

These consultations are part of DEFRA’s statutory duty to assess requests for exemptions and to ensure that any continued use of restricted substances is technically justified and time-limited. Industry stakeholders, environmental organizations, and other interested parties are encouraged to provide evidence-based feedback. Comments can be submitted until 4 May 2025 via DEFRA’s consultation portal here.

The UK has introduced the Cosmetic Products (Restriction of Chemical Substances) Regulations 2025 (SI 2025 No. 413), which will come into force on 30 September 2025. This regulation amends Annex 3 of ...

The UK has introduced the Cosmetic Products (Restriction of Chemical Substances) Regulations 2025 (SI 2025 No. 413), which will come into force on 30 September 2025. This regulation amends Annex 3 of the UK Cosmetics Regulation (retained from Regulation (EC) No 1223/2009), following the consultation launched earlier this year. The new rules set specific concentration limits, particularly for products intended for young children.

Key Details:

• Substance Affected: Methyl salicylate (CAS No. 119-36-8)

• Regulatory Changes: The amendment introduces concentration limits for methyl salicylate across various product categories, particularly those intended for children aged between 0.5 to 1 year.

• Transitional Provisions: Cosmetic products containing methyl salicylate that are placed on the market on or before 30 September 2025 may continue to be sold until 31 March 2026.

The amendment aligns with the scientific advice provided by the UK’s Scientific Advisory Group on Chemical Safety.

For full details, the official legislation is available here.

UK Environment Secretary Steve Reed has announced a national shift toward a circular economy, placing chemicals and plastics at the heart of the government’s strategy to reduce waste, improve resour...

UK Environment Secretary Steve Reed has announced a national shift toward a circular economy, placing chemicals and plastics at the heart of the government’s strategy to reduce waste, improve resource efficiency, and drive green investment. The announcement was made during a speech on 27 March 2025 in London.

Chemicals and Plastics Among Priority Sectors

The chemicals and plastics sector is one of five priority industries identified for targeted action under the upcoming Circular Economy Strategy, alongside textiles, transport, construction, and agri-food. These sectors have been chosen for their high material use and environmental impact, as well as their potential to benefit from greater circularity.

An independent Circular Economy Taskforce will collaborate with these sectors to develop roadmaps aimed at reducing waste and improving materials management. In the case of chemicals and plastics, this includes encouraging innovation in design, reuse, and recycling.

Support for Chemical Recycling and Infrastructure

The strategy, expected later in 2025, will include long-term regulatory roadmaps designed to stimulate investment in chemical recycling technologies and infrastructure. The government also aims to support domestic processing of recycled plastics, particularly for food-grade use, helping reduce reliance on virgin materials.

Work is already underway to improve verification of recycling processes, including through collaboration with the Food Standards Agency to certify food-grade recycled plastics. These measures are intended to retain the value of recycled materials in both domestic and export markets.

Policy Signals for Industry Engagement

The initiative is part of a broader effort to end the linear, throwaway economy by supporting product redesign, better waste collection, and recycling infrastructure. For the chemicals sector, this translates to stronger policy signals and regulatory stability, creating an environment that encourages the development and scaling of advanced recycling technologies.

The government estimates that circular economy reforms could unlock more than £10 billion in private sector investment. A significant share of this is expected to benefit waste treatment and recycling facilities, including those using chemical processes to recover valuable materials.