
UK Internal Market Regulations Exclude Glue Trap Sales Bans From Market Access Rules
The UK has carved out glue trap sales prohibitions from internal market access principles, enabling devolved and national restrictions to operate as intended.

The Health and Safety Executive (HSE) has published the UK REACH Work Programme for 2025/26, detailing the regulatory priorities that will shape chemical compliance in Great Britain over the coming year. The update is critical for manufacturers, importers, and downstream users across the chemicals ecosystem, setting out upcoming restrictions, authorisations, and evaluation milestones under the UK REACH Regulation.
This year’s plan focuses on finalising opinions for PFAS in firefighting foam, expanding the list of Substances of Very High Concern (SVHCs), and issuing new technical reports to support evidence-based regulation. Notably, the third recommendation of SVHCs for Annex 14 inclusion is due by 31 December 2025, and the Rolling Action Plan for 2025–27 will be submitted by 31 May 2025.
One of the most closely watched developments is the progression of a restriction proposal targeting per- and polyfluoroalkyl substances (PFAS) in firefighting foams. The HSE plans to finalise its opinion on this restriction in Q4 2025, a move that could significantly affect industries from aviation to construction.
Alongside this, HSE will make a third formal recommendation of SVHCs for inclusion in Annex 14, which would mandate authorisation for their continued use. These changes could trigger reformulations, substitution strategies, and supply chain adjustments, particularly in sectors such as electronics, consumer goods, automotive, and industrial manufacturing.
Ten substances have been selected for technical reports this year, including:
These reports aim to consolidate hazard and exposure data, informing future regulatory actions without prescribing immediate measures. Stakeholders are encouraged to monitor developments closely to assess potential compliance risks or opportunities.
In addition to technical deliverables, HSE plans to publish its next UK REACH evaluation report and a non-animal testing methods report by Q3 2025, with a new work programme and Article 83 report to follow in April 2026.




The UK has carved out glue trap sales prohibitions from internal market access principles, enabling devolved and national restrictions to operate as intended.

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