UK Regulatory News

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.

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.