ChemRegs Newsletter – March 2026

The Chemicals (Health and Safety) (Amendment, Consequential and Transitional Provision) Regulations 2026

The Department for Work and Pensions (DWP) has now laid before Parliament the draft Chemicals (Health and Safety) (Amendment, Consequential and Transitional Provision) Regulations 2026.

The Regulations use powers in the Retained EU Law (Revocation and Reform) Act 2023 to make provision for revocation, replacement and the making of alternative provision, and consequential amendments, in respect of the following 3 regulations for which it is responsible:

• GB Biocidal Products Regulation (GB BPR)
• GB Classification, Labelling and Packaging (GB CLP)
• GB Prior Informed Consent for the export and import of hazardous chemicals (GB PIC)

You can read the statutory instrument and explanatory memorandum on legislation.gov.uk.

The Regulations implement some of the changes that formed part of HSE’s public consultation on proposed reforms to chemicals legislation in GB, which you can read about in our February Newsletter.

The draft legislation will be subject to debate in the House of Commons and the House of Lords.

Defra publishes new Strategic Approach Statement on UK REACH Candidate List

(Contains public sector information licensed under the Open Government Licence v3.0.)

Defra has announced a new strategic approach to adding Substances of Very High Concern (SVHCs) to the UK REACH Candidate List.

The UK’s registration, evaluation, authorisation and restriction of chemicals regulation (UK REACH) is part of the chemicals regulatory framework for Great Britain (England, Scotland and Wales).

UK REACH is based on the principle that manufacturers, importers and downstream users should ensure that the substances they manufacture, place on the market or use do not adversely affect human health or the environment.

The regulation places responsibility on businesses to understand and manage the risks of chemicals, and communicate appropriate risk management measures along supply chains to customers.

UK REACH identifies substances of very high concern (SVHCs), which include substances with carcinogenic, mutagenic or reprotoxic properties, or those that are especially persistent and bioaccumulative in the environment.

The UK REACH candidate list constitutes those substances identified as SVHCs and serves to flag the potential for further regulatory control in future. Inclusion on the candidate list places some additional communication and notification duties on suppliers of SVHCs on their own, or in mixtures or articles.

Once on the candidate list, a substance could be considered for potential inclusion on the authorisation list. If a substance is added to the authorisation list, it cannot be used after the specified ‘sunset date’ unless the use is exempt from authorisation, or a use-specific authorisation has been granted.

When UK REACH came into force, all substances that were on the EU REACH candidate list were carried over onto the UK REACH candidate list. 

Following the UK’s exit from the EU in 2021, Defra worked with the Welsh and Scottish governments to set out interim principles for adding SVHCs to the candidate list. In 2025, the government reviewed these interim principles and from 24 February 2026, the 2021 interim principles no longer apply. Instead, the UK government has adopted a new, proactive approach to the UK REACH candidate list of Substances of Very High Concern (SVHC), focusing on faster alignment with EU REACH updates.

This approach was set out in Defra’s 2025 Environmental Improvement Plan (commitment 40) – see our December 2025 Newsletter for more information.

Substances that have been added to the EU REACH candidate list since 1 January 2021 will be reviewed and added to the UK REACH candidate list where appropriate. This approach aims to provide more certainty for industry, and to reduce business complexity – by ensuring that the UK candidate list is more closely aligned with the EU candidate list.

At the time of writing, the total number of substances currently on the UK REACH SVHC Candidate List is around 219. This is far fewer than the EU REACH Candidate List, which currently has 253 substances.

The ability for GB to propose further potential SVHCs independent of the EU is retained, where it is considered that the substances meet the criteria set out in Article 57 of UK REACH.

Although the new strategic approach will reduce the current divergence between the UK and EU REACH Regulations, the addition of more SVHCs to UK REACH candidate list will mean more supply chain communication obligations under UK REACH and may precede consideration for authorisation in the future.

Following on from the publication of the new strategic approach statement, HSE (as the Agency for UK REACH) has opened a 6-week consultation on the inclusion of 15 SVHCs on the UK REACH candidate list.

The substances are being batched to manage input from interested parties. The first batch of substances all have a mandatory classification under the GB CLP Regulation as carcinogenic, mutagenic or toxic to reproduction.

Interested parties are invited to comment and submit information on the identity or hazardous properties of these substances, with a deadline of 20 April 2026.

The Registry of SVHC Intentions Until Outcome (RoI) on HSE’s webpages has been updated and currently also contains the names of the substances to be included in the second batch for consultation in June 2026.

Harmonised classification and labelling consultation for Hydrochloric Acid

The European Chemicals Agency (ECHA) has opened a consultation on a revised harmonised classification and labelling (CLH) proposal for hydrochloric acid (EC number 231-595-7) under the EU CLP Regulation.

This CLH proposal is for aqueous solutions (i.e. “hydrochloric acid … %”, Index No. 017-002-01-X) as there is a separate EU CLP harmonised entry for the gas (hydrogen chloride, Index No 017-002-00-2).

The current harmonised classification for “hydrochloric acid … %” is Skin Corr. 1B, H314 [Causes severe skin burns and eye damage] and STOT SE 3, H335 [May cause respiratory irritation]. It also has its own specific concentration limits, which are:

Skin Corr. 1B; H314 [Causes severe skin burns and eye damage]: C ≥ 25 %
Skin Irrit. 2; H315 [Causes skin irritation]: 10 % ≤ C < 25 %
Eye Irrit. 2; H319 [Causes serious eye irritation]: 10 % ≤ C < 25 %
STOT SE 3; H335 [May cause respiratory irritation]: C ≥ 10 %

The proposed revised classification would change the current classification as follows.

Remove:

• STOT SE 3, H335 [May cause respiratory irritation]
• The specific concentration limits

Add:

• Met. Corr. 1, H290 [May be corrosive to metals]
• Acute Tox. 3, H301 [Toxic if swallowed]
• Acute Tox. 3, H331 [Toxic if inhaled]
• Eye Dam. 1, H318 [Causes serious eye damage]
• EUH071 [Corrosive to the respiratory tract]
• Inhalation ATE = 0.5 mg/L (dust/mist)
• Inhalation ATE = 3.0 mg/L (vapour)
• Oral ATE = 100 mg/kg bw

Modify:

• Skin Corr. 1B, H314 to become Skin Corr. 1, H314
• GHS pictograms and signal word from GHS05, GHS07, Dgr to become GHS05, GHS06, Dgr

This would make the resulting harmonised classification and labelling for hydrochloric acid … %:

Met. Corr. 1, H290
Acute Tox. 3, H301
Acute Tox. 3, H331
Skin Corr. 1, H314
Eye Dam. 1, H318

EUH071

Inhalation ATE = 0.5 mg/L (dust/mist)
Inhalation ATE = 3.0 mg/L (vapour)
Oral ATE = 100 mg/kg bw

GHS05
GHS06
Dgr

Parties concerned are invited to comment on the CLH revisions and the deadline for commenting is 18 May 2026.

Please note that the CLH proposal is only for the EU, as Great Britain has not yet implemented any proposals for changes to the classification under GB CLP.

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