UK Regulatory News

On 8 May 2025, the United Kingdom formally notified the World Trade Organization (WTO) of a new regulatory measure titled the Cosmetic Products (Restriction of Chemical Substances) Regulations 2025. T...

On 8 May 2025, the United Kingdom formally notified the World Trade Organization (WTO) of a new regulatory measure titled the Cosmetic Products (Restriction of Chemical Substances) Regulations 2025. This step aims to strengthen consumer protection by revising the permitted levels of benzophenone-3, a common UV-filter used in cosmetic products.

The amendment, which modifies the Cosmetics Regulation (EC No 1223/2009) as it applies in Great Britain, follows expert guidance from the Scientific Advisory Group on Chemical Safety of Non-Food and Non-Medicinal Consumer Products (SAG-CS). The group advises the UK Government independently on chemical risks in consumer goods, with a strong emphasis on safeguarding public health.

Implementation Timeline

Effective Date: 21 January 2026

Transitional Period: Products containing benzophenone-3 already on the market before this date may remain available until 21 July 2026

This move aligns with the UK’s commitment to ensure that only safe cosmetic products are accessible to consumers, reflecting evolving scientific risk assessments and reinforcing public trust in regulatory vigilance.

The UK Government has launched a public consultation on proposals to extend the transitional registration submission deadlines under UK REACH further. Published on 14 July 2025 by the Department for E...

The UK Government has launched a public consultation on proposals to extend the transitional registration submission deadlines under UK REACH further. Published on 14 July 2025 by the Department for Environment, Food & Rural Affairs (Defra), he consultation is open for comments until 8 September 2025.

The current phased deadlines - October 2026, October 2028, and October 2030 - apply to transitional registrations based on the tonnage and hazard profile of the substances. These obligations affect companies placing chemical substances on the market in Great Britain (England, Scotland, and Wales) that were previously registered under EU REACH, but which must now be registered under UK REACH.

Current UK REACH Transitional Registration Deadlines:

Not the First Extension

This is not the first time that the transitional registration deadlines have been extended. The original deadlines were set for 27 October 2023, 2025, and 2027. However, following stakeholder concerns about the feasibility of timely compliance, the government consulted on postponement options in early 2023. As a result, the deadlines were formally extended by three years via Statutory Instrument 2023/722, which was adopted in July 2023.

More details on that decision are available here and here.

Proposals for Further Delay

As the Alternative Transitional Registration model (ATRm) is still under development, the government is now proposing a second round of deadline extensions. The ATRm is expected to define revised, more proportionate data requirements for transitional registrations. However, the current administration has not yet finalised its implementation, and it is unlikely to be ready in time for the first deadline in 2026.

The consultation presents three options:

Compliance Check Timing Also Under Review

The consultation also seeks views on aligning the HSE’s duty to conduct compliance checks (on 20% of dossiers, as per Article 41(5) of UK REACH) with any revised submission deadlines. This ensures that regulatory oversight keeps pace with the updated registration timeline.

Consultation Access

Stakeholders are encouraged to submit their feedback before 8 September 2025. The consultation can be accessed here.

On 10 July 2025, the UK government published its final decision to restrict the use and placing on the market of lead in ammunition under UK REACH. Adopted by the Department for Environment, Food and ...

On 10 July 2025, the UK government published its final decision to restrict the use and placing on the market of lead in ammunition under UK REACH. Adopted by the Department for Environment, Food and Rural Affairs (DEFRA) on 27 June 2025, the restriction aims to address the significant risks posed by lead ammunition to wildlife, the environment, and human health.

Following the restriction dossier prepared by the Health and Safety Executive (HSE) and the Environment Agency, the decision introduces a phased approach to limit the use of lead shot, bullets, and airgun pellets for hunting, sports shooting, and outdoor target shooting.

Scope and Application of the Restriction

The restriction applies to:

• Lead shot used in hunting and sports shooting with shotguns.

• Lead bullets used for rifle hunting and outdoor target shooting.

• Lead used in airgun pellets.

The measures specifically target shooting activities conducted outside licensed ranges. However, certain uses, such as those by the military, the police, and licensed indoor shooting ranges, are exempted from the restriction.

Phased Implementation with Transition Periods

The restriction will be introduced in phases to allow industry and shooters time to adapt:

• Lead shot: The ban will take effect after a three-year transition period for most uses.

• Lead bullets: The ban comes into force after 5 years for hunting and sports shooting.

• Airgun pellets: An 18-year transition period is provided to allow for technical developments.

Derogations are provided in cases where non-lead alternatives are not yet available or practical.

Key Reasons Behind the Restriction

The decision is driven by the well-documented risks associated with lead in ammunition.

• Wildlife Impact: Lead poisoning from ammunition affects millions of birds each year, including waterfowl and raptors.

• Human Health Risks: Consuming wild game containing lead fragments can expose humans to lead, with vulnerable groups such as children being particularly at risk.

• Environmental Harm: Lead residues persist in soils and waterways, causing long-term ecological damage.

The restriction is expected to bring significant health and environmental benefits while balancing the socio-economic impacts on shooting sports and ammunition manufacturers.

Background: UK’s Ongoing Efforts to Address Lead in Ammunition

The adoption of the restriction follows the restriction dossier published in May 2023, which proposed the control of lead in ammunition under UK REACH. This initial proposal set out the scientific and socio-economic assessments that paved the way for this final decision. Further details can be found here.

This reflects the UK’s commitment to environmental protection and the responsible management of hazardous substances.

UK REACH Restriction Now in Force

With the final decision now published, the restriction on lead in ammunition under UK REACH is now legally binding. The phased transition periods allow time for adaptation, but the UK has taken a decisive step to protect public health, wildlife, and the environment from the well-established dangers of lead exposure.

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 unti...

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 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.