GB Chemicals Legislative Reform: HSE Confirms EU-Only Recognition and Call-In Overhaul

The consultation, which ran from 23 June to 18 August 2025, received more than 280 responses from businesses, trade bodies, NGOs and members of the public. Stakeholders across the chemicals value chain closely scrutinised proposals affecting biocides, classification and labelling, and export controls.

GB BPR Reform: EU Recognition and Risk-Based Call-In

Under the revised approach to GB BPR, HSE will introduce legislative changes enabling recognition of EU biocidal active substance approvals and product authorisations. The EU will be the only recognised jurisdiction. This move is designed to address a backlog of around 330 active substance and product type evaluations inherited after EU Exit and to reduce evaluation costs that can reach £160,000 per active substance.

In parallel, HSE plans to replace fixed renewal dates with a risk-based call-in system. Instead of automatic expiry, substances will be reviewed when new evidence or risk triggers justify reassessment. HSE argues this will allow regulatory effort to focus on higher-risk substances while maintaining non-regression commitments under the UK–EU Trade and Cooperation Agreement.

Temporary postponement of up to 173 active substance expiry dates from January 2027 is planned while primary legislation is developed.

GB CLP Changes: Faster Classifications and UK Internal Market Alignment

For GB CLP, HSE will remove the automatic statutory link to ECHA’s Risk Assessment Committee opinions, replacing it with a fast-track evaluation route for EU classifications. This is intended to improve agility while still aligning with EU hazard decisions in most cases.

HSE also confirmed it will amend GB CLP to safeguard the UK Internal Market by applying a consistent regime across Great Britain and Northern Ireland, particularly in response to recent EU CLP revisions and the 6th Simplification Omnibus. At least six months’ lead time will be provided before labelling changes take effect in Northern Ireland and the EU.

Additionally, the GB notification database will be revoked to reduce administrative burdens, with oversight maintained through existing labelling and data obligations.

GB PIC Simplification and International Obligations

Under GB PIC, HSE will remove the Special Reference Identification Number procedure and amend the waiver process for explicit consent, aligning more closely with the Rotterdam Convention while reducing administrative friction.

New general powers are proposed to allow future amendments via primary legislation, ensuring that GB PIC can keep pace with international developments.

Implications for Industry

Manufacturers, importers, downstream users and exporters should prepare for procedural shifts rather than substantive lowering of standards. The repeated emphasis on EU alignment signals regulatory stability for businesses trading with both GB and EU markets, while the call-in model may alter long-term compliance planning cycles.

Companies should review active substance portfolios, monitor forthcoming primary legislation, and assess how removal of notification and SRIN requirements may affect internal compliance systems.

Summary

HSE’s Chemicals Legislative Reform response confirms a strategic pivot towards EU-only recognition, risk-based biocides oversight and streamlined GB CLP and GB PIC processes. While procedural burdens may ease, high protection standards remain intact, and alignment with the EU continues to shape GB chemicals regulation.