UK Chemical Regulation: Why alignment with the EU is necessary for protection against harmful chemicals.

Chemical pollution in the UK is reaching critical levels 

The UK environment is being impacted by high levels of chemical pollution, with not a single river in England achieving good chemical status1. A cocktail of industrial chemicals are contaminating everyday consumer products, agricultural inputs, wastewater and sludge by-products. Through numerous direct and diffuse pathways, these chemicals are entering our air, soil, waterways and marine environments. Driven in part by chemical pollution, the UK’s biodiversity and essential ecosystems are in peril with nearly one in six species under threat of extinction in Great Britain2. Harmful chemicals are also increasingly linked to health concerns such as cancer, fertility, and neurological issues. Chemical pollution has reached critical levels in the UK with the River Mersey Basin cited as one of the most PFAS polluted watersheds in the world3. This is due to a lack of restrictions preventing PFAS emissions at source in the UK and an allowance of widespread direct and diffuse discharges of these ‘forever chemicals’ into the environment. Getting chemical pollution under control requires robust regulation – aligning UK chemical regulation with the world leading EU regulations would pave the way for pollution prevention.  

Failing to Keep Pace: UK REACH 

The key chemical regulation in Great Britain (Scotland, England and Wales), UK REACH, is failing to restrict harmful chemicals, leading to unacceptable environmental pollution and harm to people and wildlife. Since the UK left the EU on January 1, 2021, the UK has not restricted any harmful chemicals (see divergence table at bottom of page), while the EU has implemented ten, including a wide reaching ban on intentionally added microplastics and a group restriction on bisphenols in food contact materials. The EU is also progressing with significantly more ambitious measures on the ‘forever chemicals’, PFAS, including a proposed universal restriction on all PFAS for all but essential uses, whereas the UK is currently progressing with one sector-specific restriction and proposals cover a much smaller number of chemicals within the same group and is more limited on products and uses. Under the Northern Ireland Protocol, EU REACH Regulation continues to apply to Northern Ireland (NI).  The divergence between the EU (& NI) and Great Britain is growing, this means that citizens and wildlife in England, Scotland and Wales are less protected than those in Ireland or the rest of Europe. 

Although UK REACH in theory works in a similar way to EU REACH, from which it was copied, there is reduced capacity and without the scale of expertise and resources drawn from all member states, the UK system is failing to identify and restrict chemicals of concern. A 2024 Defra consultation proposed reducing the amount of data that industries have to provide on chemicals in the UK market, further undermining the UK’s ability to take regulatory decisions and industries ability to manage risks (see Fidra’s blog). Aligning UK chemical regulations with the world leading EU regulations would ensure regulations in the UK are based on the most comprehensive data and are up to date. 

Failing to identify hazards: GB Classification, Labeling and Packaging Regulation 

The classification of chemical hazards helps identify harmful chemicals and allows regulators to keep them out of certain products like toys. It also informs risk management in workplaces. Once a chemical is classified as toxic or carcinogenic, this can then also lead to further regulations to phase it out. In Great Britain, classification is led by the Health and Safety Executive and our current regulation requires the regulator to consider EU classifications. However, Enhesa analysis of GB CLP (in November 2023) found that GB CLP diverged from the EU’s in just under 15% of classifications, and found in these instances of divergence, GB CLP was “generally less strict”. Specifically, it found that the EU classification is stricter than the British equivalent for 12 of those 15 diverging substances, or 80% of the time4. In 2023, the EU introduced new classifications to address the dangers posed by certain chemicals, including endocrine-disrupting substances known to interfere with hormones and contribute to conditions like breast cancer. These new classifications have not been implemented in the UK. De-coupling the GB Classification Labelling and Packaging from the EU, risks creating a hard border in Northern Ireland and will continue to result in less protective measures for the environment and GB citizens. 

Benefits of Aligning with Europe on Chemicals

  • Stronger Public & Environmental Health Protections – Improves worker safety, women’s health, and pollution control. Backed by public 5 . 

  • Lower Clean-Up Costs – Prevents pollution and saves the UK up to £9.9 billion annually in PFAS clean-up costs 6.    

  • Eases Regulatory Burden – Reduces administrative costs, minimises data duplication, and enhances enforcement.

  • Boosts Trade & Business Certainty – Strengthens the GB Brand, facilitates EU trade, and provides stability for businesses.

  • Prevents a Hard Border in Northern Ireland – Ensures smoother trade and regulatory consistency across the UK.

  • Supports a Circular Economy – Reduces harmful chemicals and promotes the safe reuse of materials (see Fidra report). 

  • Drives Innovation & Green Chemistry – Keeps the UK at the forefront of sustainable chemical advancements.

  • Backed by Industry – Manufacturers, retailers, recyclers, and water companies support better chemical control.

Key Ask for the UK Government

Fidra are calling on the UK Government to actively pursue dynamic alignment with Europe on chemicals as part of the EU/UK reset and achieve alignment by 2029.

Interim Asks 

  • Commit to matching European chemical regulations in the revised Environment Improvement Plan (Outcome 4) 
  • Once a commitment has been made to match EU chemical regulations as a minimum, enact relevant legislation in the UK to enable the UK to easily adopt EU REACH restrictions (similar to the Swiss Model7) 

Once a clear commitment to align is stated in the EIP, there is nothing to prevent the UK moving quicker than the EC on critical issues, as we have seen with the PFAS restrictions in Denmark and France.

divergence table
Divergence Table
Alignment Position

References 

1 Bevan, J. (2020). The state of our waters: the facts. Environment Agency. https://environmentagency.blog.gov.uk/2020/10/02/the-state-of-our-waters-the-facts/ 

2 Burns, F., Mordue, S., al Fulaij, N., et al. (2023). State of Nature Report 2023. State of Nature Partnership, www.stateofnature.org.uk. 

3 Hosea, L., and Salvidge, R. (2024, February 18). River Mersey forever chemical loads among the largest in the world. https://www.endsreport.com/article/1861887/river-mersey-forever-chemical-loads-among-largest-world 

4 Enhesa/Chemical Watch. (2023). Post-Brexit mandatory classifications that diverge from EU CLP generally less strict, analysis finds. Chemical Watch News. 09 November 2023. https://product.enhesa.com/883141 

5 Clay, P. (2022). Protect or deregulate? A review of public attitudes to regulation. Unchecked UK. https://unchecked.uk/wp-content/uploads/2022/09/UnChecked_PublicAttitudesToRegulation-FINAL.pdf 

6 Forever Lobbying Project (Forever Pollution Project). (2025). The Cost of Remediation. https://foreverpollution.eu/lobbying/the-cost-of-remediation/ 

7 Roberts, G. (2023). The Swiss Chemicals System, the legal framework and how it relates to that in the EU. A report for CHEM Trust. https://chemtrust.org/wp-content/uploads/Swiss-chemicals-regulatory-system-report-FINAL-.pdf