ChemRegs Newsletter – December 2025

UK REACH Reforms

On 1 December 2025, the Department for the Environment, Food and Rural Affairs (Defra) published its revised 2025 Environmental Improvement Plan (EIP25), which sets out a road map for improving the natural environment in England.

This follows on from the 2021 Environment Act, which established legally binding targets for environmental improvement and required the publication of Environmental Improvement Plans (EIPs) detailing how these targets would be achieved. Following a review of the previous plan (EIP23), completed on 30 January 2025, the government released a summary of its principal findings.

As a result, the newly published EIP outlines ten goals and the approach for achieving them, with the primary goal of restoring nature. It describes measures the government will take to protect and rejuvenate green spaces and wildlife, enhance biodiversity, develop a circular economy, ensure environmental security, and improve public access to natural spaces.

Goal 4 of the EIP25 is to “minimise environmental risks from chemicals and pesticides”. To support this, the EIP sets out key commitments, including the reform of UK REACH.

Commitment 40: Reform UK Registration, Evaluation, Authorisation, and Restriction of Chemicals (REACH) to enable protections that address chemical pollution to be applied more quickly, efficiently and in a way that is more aligned with our closest trading partners, especially the EU, by December 2028.

Actions for commitment 40

• Defra to take regulatory decisions made by other trusted jurisdictions as the starting point for UK regulatory decisions to enable new protections to be applied more quickly and more efficiently, and to align regulation more closely with the UK’s closest trading partners unless there are compelling reasons to diverge. The aim is to protect people and the environment while reducing business complexity and trade barriers and provide industry with the certainty they need to grow and invest.
• Defra to extend the industry deadlines for submitting transitional registration data under UK REACH, through legislation to be made by October 2026, following consultation which launched in July 2025.
• Defra, Health and Safety Executive (HSE), Environment Agency (EA) to work in partnership with the devolved governments of Scotland and Wales, to implement a UK REACH restriction on lead in ammunition via legislation to be made by the end of August 2026.
• Defra, HSE to assess and, where appropriate, add substances to Annex XIV of UK REACH (‘the Authorisation List’) by the end of December 2027 to manage the risks they pose, and to encourage industry to use alternatives.
• Defra, HSE to run the UK REACH authorisation process, to ensure that the risks related to substances of very high concern (SVHCs) on the Authorisation List are properly controlled and encourage their replacement.
• HSE to publish an annual UK REACH work programme to set out priorities for UK REACH.
• Defra to review the interim principles for additions to the UK REACH Candidate List of SVHCs by the end of December 2026, with a view to updating the Candidate List.

EIP25 includes further commitments relevant to chemical management.

Commitment 41 is to take action on PFAS through a new PFAS plan to be published in 2026. In this plan, Defra will set out a range of regulatory and non-regulatory interventions, measures and initiatives with specific actions and delivery milestones. These will raise understanding and awareness of PFAS in the environment, identify and address releases of harmful PFAS and protect people and the environment from harm relating to PFAS exposure. The plan will set out a coordinated response, extending across government and industry.

The EA will provide advice, guidance and tools to support the management of PFAS at contaminated sites on an ongoing basis in response to contamination becoming apparent. This includes ensuring that technical guidance and tools are reviewed and updated as necessary.

Defra, HSE, EA will also make a decision in 2027 on implementing a potential UK REACH restriction on PFAS in firefighting foams, based on a prior proposal to be provided by the HSE and with the consent of the devolved governments of Scotland and Wales.

Commitment 42 covers the implementation of obligations under international agreements, including updates to the Stockholm Convention on persistent organic pollutants (POPs), and new restrictions on mercury-added products under the Minamata Convention.

Commitment 43 sets out actions to increase the destruction of POPs found in waste by 2030, including compliance campaigns, sampling, testing and enhanced regulatory oversight at waste treatment sites.

Commitment 44 focuses on eliminating the use of polychlorinated biphenyls (PCBs) in equipment by the end of 2025. This includes enforcement against equipment used beyond legal deadlines, as well as ensuring proper decontamination or disposal.

The full text of the Environmental Improvement Plan 2025 can be found here.

Consultation launched on the Control of Asbestos Regulations and guidance

HSE has launched a consultation on proposals to improve the application of the Control of Asbestos Regulations 2012 and guidance around asbestos management to help protect workers and building users.

The consultation aims to seek stakeholders’ views on 3 proposals:

• To ensure the independence and impartiality of roles in the four-stage clearance process to further minimise the risk of exposure from asbestos to workers and building users after the removal of asbestos
• To drive up the standard of asbestos surveys to ensure dutyholders have the information they need to safely manage asbestos risks
• To clarify the type of work that constitutes work with asbestos known as Notifiable Non-Licensed Work (NNLW)

The consultation is particularly relevant to dutyholders, asbestos analysts, asbestos removal contractors, asbestos surveyors, and associated professions including facilities management and construction.

Rick Brunt, Director of Engagement and Policy at HSE, said:

“Asbestos continues to be a significant risk to workers in Great Britain. While we have made significant progress in managing asbestos risks, these proposals represent an important step towards further strengthening protections for workers and the public.

“We want to hear from all stakeholders involved in the asbestos regulatory system to ensure our approach is both effective and proportionate, supporting HSE’s commitment to protecting people and places whilst enabling innovation and economic growth.”

The full consultation document, including detailed proposals, background information and how to respond, is available at Legislative and guidance proposals for the Control of Asbestos Regulations 2012.

The consultation is open for comments until 9 January 2026.

Contains public sector information published by the Health and Safety Executive and licensed under the Open Government Licence

IMDG 42-24

The latest amendment of the International Maritime Dangerous Goods (IMDG) Code 2024 Edition (42-24) becomes mandatory on 1 January 2026 (it could be applied voluntarily from 1 January 2025).

This means that the 2022 Edition (41-22) of the IMDG Code, which came into force on 1 January 2024, will no longer be valid from 31 December 2025.

All stakeholders – shippers, forwarders, booking staff and container packers – must ensure their procedures and training are up to date to reflect the changes in the new code.

To support industry in meeting its responsibilities, the TT Club and the UK P&I Club have jointly published the latest edition of Book it Right and Pack it Tight – Guidance on packing dangerous goods for carriage by sea – IMDG Code Amendment 42-24 in November 2025. This useful guide distils the operational steps required when booking and packing dangerous goods for carriage by sea.

The publication is in two parts:

• Part A breaks down the process into clear steps: classification, packaging, marking and labelling, documentation, segregation, packing and certification.
• Part B provides essential reference material on classification, terminology and common issues such as limited quantities and segregation.

You can download a copy of Book it Right and Pack it Tight from here.

MERRY CHRISTMAS AND A VERY HAPPY NEW YEAR!!

We would like to wish you all a very Happy Christmas and a peaceful New Year

For more information on anything in this Newsletter, please contact us at info@chemregs.co.uk