March 3, 2026 by Rhiannon Smith

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Over the summer of 2025, the Health and Safety Executive (HSE) held a consultation on reforms to chemical legislation in Great Britain (GB), which had been retained from the equivalent regulations in the European Union (EU) after Brexit. HSE’s response to this consultation has recently been published. For GB Classification, Labelling and Packaging (GB CLP), a summary of HSE’s response to the consultation is given below.

HSE propose to continue with the suggestion put forward in the consultation to remove the statutory requirement for them to consider all RAC opinions. This is proposed to streamline HSE processes, allowing them to focus on substances that are of relevance to the GB market (and ignore substances which are not on the GB market). However, HSE would still be obliged to evaluate substances with carcinogenic, mutagenic, reproductive toxic and respiratory sensitisation hazards, which is a legal requirement.

The consultation also discussed fast-tracking classifications from other territories that had adopted UN GHS (United Nations Globally Harmonised System), so that HSE would not have to repeat the evaluation (except under exceptional circumstances where HSE may wish to conduct further evaluation themselves). HSE’s response clarified that this will be restricted to the EU and, although the fast-tracked evaluations would be based on the RAC (EU risk assessment committee) opinions, GB MCL (mandatory classification and labelling) changes will continue to be made through a publicly available technical assessment prepared by HSE.

The consultation outcome notes HSE would consider, on a case-by-case basis, RAC opinions on the EU-specific hazard classes (i.e. human health and environmental endocrine disruption; Persistent, Bioaccumulative, Toxic; very Persistent, very Bioaccumulative; Persistent, Mobile, Toxic; very Persistent, very Mobile). HSE is currently considering how to incorporate these hazard classes under GB CLP but raised concerns that these could be removed or significantly amended as part of ongoing reviews to EU CLP.

HSE propose to continue with the suggestion put forward in the consultation to revoke the GB notification database on the basis that the same information is present on the chemical’s label and that the information and the supporting data would to be made available to HSE on request. Relocating explanatory technical notes to GB MCL List to HSE’s website, with the notes to be included in the same area as the GB MCL List, introducing powers to make future amendments to GB CLP and incorporating measures from EU CLP into GB CLP to mitigate potential frictions within the UK Internal Market (i.e. between Great Britain (GB) and Northern Ireland (NI)) are all also proposed to go ahead. The consultation outcome also proposed to introduce a GB MCL workplan, which will increase awareness of the classification proposals HSE intends to consider and the timing of this activity.

If you would like to read further about UK and EU chemical regulations, see the sections of our website. If you have any questions or would like to discuss any of these topics further, please do not hesitate to contact us.