UK Regulatory News

The UK Food Standards Agency (FSA) has opened a public consultation on a proposal to ban the use of bisphenol A (BPA), other bisphenols, and bisphenol derivatives in materials and articles intended...

The UK Food Standards Agency (FSA) has opened a public consultation on a proposal to ban the use of bisphenol A (BPA), other bisphenols, and bisphenol derivatives in materials and articles intended to come into contact with food. The consultation is open until 24 December 2025.

Scope and Objective

The proposal aims to prohibit the use of BPA and related bisphenols in the manufacture of food contact materials and articles, including coatings, plastics, and packaging such as metal can linings and reusable bottles. The aim is to address potential health risks associated with bisphenols, particularly their endocrine-disrupting and immunotoxic effects, and to ensure a high level of consumer protection.

Regulatory Context

This initiative follows recent scientific evidence, including the European Food Safety Authority’s (EFSA) 2023 opinion which significantly lowered the tolerable daily intake for BPA due to its potential adverse effects. The proposal also aligns with the European Union’s Commission Regulation (EU) 2024/3190, which bans BPA, its salts, other hazardous bisphenols, and bisphenol derivatives in a wide range of food contact materials. This EU regulation came into force in January 2025, providing an 18-month transition period for most products to allow for industry adaptation. Under the Windsor Framework, this regulation applies in Northern Ireland.

Substances Concerned

The proposed UK ban covers bisphenol A (BPA; CAS 80-05-7), and its analogues, such as bisphenol S (BPS; CAS 80-09-1) and bisphenol F (BPF; CAS 620-92-8). All of these substances are currently authorised under assimilated Regulation (EU) No 10/2011 on plastic materials and articles intended to come into contact with food.

Policy Options Considered

Before selecting its preferred approach, the FSA evaluated three regulatory options:

• Option 1: Take no immediate action, which would maintain the status quo but fail to address known health risks.
• Option 2: Ban BPA only, which could result in substitution with structurally similar bisphenols that may pose comparable risks.
• Option 3 (preferred): Ban both BPA and its analogues, offering the most comprehensive protection for public health and ensuring alignment with international developments, including the EU ban.

The FSA concluded that Option 3 best reflects the precautionary principle and provides the strongest level of consumer protection. The consultation therefore focuses on gathering views on the implementation details of this option, such as its scope, potential exemptions, and transition periods.

Next Steps

Stakeholders, including manufacturers, importers, retailers, and consumers, are invited to submit comments via the FSA consultation portal by 17:00 UK time on 24 December 2025. Following the consultation, the FSA will review the responses and make recommendations to UK ministers regarding implementation and potential transition measures.

The proposal reflects the precautionary principle and seeks to ensure consistency with EU developments while strengthening consumer safety across the UK market.

On 16 September 2025, the UK Health and Safety Executive (HSE) released the seventh edition of the Great Britain (GB) Mandatory Classification and Labelling (MCL) list. This latest update introduce...

On 16 September 2025, the UK Health and Safety Executive (HSE) released the seventh edition of the Great Britain (GB) Mandatory Classification and Labelling (MCL) list. This latest update introduces new and revised mandatory classifications for 30 hazardous substances, based on the fifth GB CLP Agency recommendation formally agreed by Ministers in September 2025.

The changes were first notified to the World Trade Organization (WTO) under reference G/TBT/N/GBR/101 on 7 April 2025, giving stakeholders the opportunity to review and comment on the proposal.

Background on the GB MCL

The GB MCL list is a legally binding register of classifications maintained by HSE under the GB CLP Regulation. It provides a consistent framework for the classification and labelling of substances and mixtures across Great Britain (England, Scotland, and Wales). The list underpins regulatory obligations for manufacturers, importers, downstream users, and distributors, ensuring accurate hazard communication and supporting the protection of human health and the environment.

The GB MCL is updated on a regular basis to reflect scientific advances, regulatory decisions, and international developments. Updates may involve the addition of new substances, changes to existing classifications, and editorial improvements to ensure clarity and accuracy.

Key Highlights of the 7th Edition

• New Classifications: The update introduces new classifications for 30 hazardous chemical substances, including substances such as perboric acid (sodium salt), disodium peroxoborate and ozone. Furthermore, Pigment Red 122 and Solvent Violet 13 have been added, both of which are commonly used in tattoo inks and cosmetics and have been the subject of regulatory scrutiny in Europe.
• These classifications were evaluated by the HSE and recommended by the GB CLP Agency. The full list of substances is available in the WTO notification here  and on the HSE website here.
• Compliance Timeline: The Secretary of State’s Decision was issued on 12 September 2025, with the new and revised classifications entering into legal effect on 23 September 2025. Stakeholders must ensure compliance by the final deadline of 23 March 2027.
• Corrections and Clarifications: The 7th edition also corrects a number of editorial errors and typos from earlier versions of the GB MCL and removes duplicate entries to improve consistency.

Next Steps for Stakeholders

Stakeholders should review the updated list and prepare for the transition period ahead of the 2028 compliance deadline. The GB MCL list and the HSE GB CLP Publication Table here provide detailed information on the updated entries, including the Agency Opinions supporting each classification.

The UK Health and Safety Executive (HSE) has launched a six-month public consultation on a proposed restriction of per- and polyfluoroalkyl substances (PFAS) in firefighting foams under UK REACH. T...

The UK Health and Safety Executive (HSE) has launched a six-month public consultation on a proposed restriction of per- and polyfluoroalkyl substances (PFAS) in firefighting foams under UK REACH. The consultation will run until 18 February 2026.

Scope of the Proposal

The restriction targets PFAS used in firefighting foams, covering their manufacture, placing on the market, use, storage, and disposal. PFAS are defined to include substances containing at least one fully fluorinated carbon atom (-CF₂ or -CF₃) without hydrogen, chlorine, bromine, or iodine substituents. The proposal includes transition periods tailored to sectors to allow operators time to adopt PFAS-free alternatives.

Risks and Rationale

According to the Annex 15 restriction dossier, PFAS in firefighting foams present significant threats to human health and the environment. Their persistence, mobility, and potential for bioaccumulation mean that existing controls are insufficient to protect against exposure. Firefighting foams are highlighted as a key source of PFAS emissions, especially via runoff into soil and water systems when used outdoors.

Next Steps

Once the consultation closes, the HSE will review stakeholder submissions and issue its final opinion. That opinion will be forwarded to the Secretary of State for Environment, Food & Rural Affairs and to the devolved administrations for a decision.

The consultation documents, including the full Annex 15 dossier, are available on the HSE site here

On 6 August 2025, the UK Health and Safety Executive (HSE) issued a bulletin reminding companies exporting chemicals listed under the GB Prior Informed Consent (PIC) Regulation that they must submi...

On 6 August 2025, the UK Health and Safety Executive (HSE) issued a bulletin reminding companies exporting chemicals listed under the GB Prior Informed Consent (PIC) Regulation that they must submit export notifications at least 35 days before the first shipment in 2026. This requirement applies to exports to all countries, including Northern Ireland.

Submission Requirements

Export notifications must be sent to ukdna@hse.gov.uk using the GB PIC export notification form. Each email should cover a single chemical or mixture and include a Safety Data Sheet (SDS) in English and, where available, in the official language of the importing country. Where no SDS is provided, sections 4 and 5 of the notification form must be completed. The intended use should be clearly stated to facilitate processing by the importing authority.

Mixtures with the same classification, labelling, and use can be covered by one notification, provided concentration changes do not affect labelling.

Special RIN Applications

For exports intended solely for research or analysis, and for quantities up to 10 kg per year per importing country, companies may apply for a Special Reference Identification Number (Special RIN). This also applies when an importing country has waived the notification requirement under the Rotterdam Convention. Requests should be submitted to HSE using the Special RIN form or the bulk RIN option.

Further details and forms are available in the bulletin here. 

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.