The UK Health and Safety Executive (HSE) has launched a public consultation proposing major reforms to three core areas of Great Britain’s chemical regulations—Biocidal Products (BPR), Classification, Labelling and Packaging (CLP), and Prior Informed Consent (PIC). Running until 18 August 2025, the proposals aim to reduce administrative burdens, support innovation, and align UK rules with international standards while maintaining high levels of health and environmental protection.
Professionals across the manufacturing, logistics, retail, and chemical supply chain sectors are advised to review these changes, which could significantly affect compliance duties, market access, and regulatory reporting.
Key Changes to Biocidal Products Regulation
The proposed BPR reforms are designed to modernise the regulation of biocidal active substances and products in Great Britain. One major proposal is to recognise approvals from trusted international jurisdictions—such as the EU—eliminating the need for duplicate evaluations. This could reduce application fees by over 95%, from approximately £160,000 to £5,000.
Another transformative proposal is to remove fixed expiry dates for substance approvals. Instead, HSE would "call in" substances for review based on emerging risk. This risk-based approach aims to allow regulators to prioritise evaluations and avoid unnecessary renewals, potentially freeing up resources and shortening regulatory timelines.
Additionally, the reforms propose broader use of “essential use” provisions, enabling temporary approval of products critical to public health or infrastructure even when full compliance is not yet achieved.
Updates to CLP Will Impact Label and Data Duties
Under the proposed CLP changes, HSE would consolidate Articles 37 and 37A into a single, simplified process for mandatory classifications. This would end the obligation to evaluate all EU RAC opinions, allowing HSE to focus on substances relevant to the GB market.
A new fast-track evaluation process is also planned for classifications from jurisdictions using the UN Globally Harmonised System (GHS), reducing the timeline for decisions from 24 to 12 months.
Crucially, the Article 40 notification requirement—currently obliging suppliers to notify HSE when placing new substances on the GB market—would be revoked. HSE contends this step adds little enforcement value and imposes unnecessary burdens on business.
PIC Changes Aim to Simplify Hazardous Exports
For the Prior Informed Consent regime, HSE proposes eliminating the Special Reference Identification Number (SRIN) procedure, a legacy mechanism that has no utility in current enforcement or international coordination. This would simplify the export process for small quantities used in research.
Also under review is the waiver process for explicit import consent. HSE plans to standardise the criteria for all substances requiring consent, replacing a patchwork of rules with a consistent, risk-based model.
Implications for Industry
Stakeholders across the chemicals ecosystem—from manufacturers and distributors to logistics and downstream users—stand to benefit from reduced costs and clearer compliance frameworks. However, divergence between GB and EU rules, especially for businesses operating in or through Northern Ireland, remains a consideration.
The proposed changes reflect a broader UK regulatory strategy to boost growth, simplify compliance, and enhance market access, while preserving health and environmental standards.
