Over the last decade, environmental and chemical policies have started to play a larger role across the globe. The UK previously played a major role in setting policy and performing evaluations in the EU. Due to the impact of Brexit, the UK may take a more international viewpoint when developing its own environmental and chemical policies. This may ultimately lead to divergence between the UK and EU, which will have a huge impact on the chemical industry as companies will need to ensure compliance with both regimes. This may create stumbling blocks for companies supplying chemical products to the UK and EU, and manufacturing companies with sites in both jurisdictions.

EU’s Strategy:

In December 2019, the European Commission revealed its new EU Green Deal, which sets out numerous ambitious targets including being carbon neutral by 2050, zero pollution and making decisions on environmentally responsible projects. By the summer 2020, an EU chemicals strategy for sustainability is expected to be launched to support these targets. The aim of this strategy is to ensure a toxic-free environment and will highlight how the regulatory framework needs to reflect scientific evidence on the risk of endocrine disruptors, combination effects and very persistent chemicals.

UK’s Strategy:

In parallel, the UK government has been working on its 25-year Environment Plan since January 2018. Progress has been slow, but it is now expected that work will ramp up on the chemical strategy during 2020. Defra has announced that there will be a call for evidence in late spring 2020 and the final document due for release in 2022. This chemical strategy aims to tackle chemicals that are of national concern while building on existing approaches with the top three actions concerning polychlorinated biphenyls (PCBs), mercury and persistent organic pollutants (POPs).

What this means for industry:

It is probable that, due to Brexit, the UK will have to implement its own versions of existing EU chemical specific regulations such as REACH, CLP and BPR which may lead to similar parallel systems with the same goals. The UK government does not want a second-best chemical regime; this will have knock-on effects for industry, in particular, the cost of accessing data to support their submissions in the two separate jurisdictions. The UK government has previously stated that it would review all EU authorisations in the future with the view to including them in its own authorisation list, while concurrently reviewing data on its own priority list of substances. This may be the first area to diverge between the two systems. There could be similar impacts to the chemical waste sector regarding the European BREF note and BAT conclusions guidance document which is currently being consulted on. It is likely that the UK could potentially diverge from such requirements.

Why your contribution is so crucial

The EU green deal and the UK 25-year environment plan will influence and shape the supporting chemical regimes in those countries. Industry should, where possible, provide comments and feedback during consultations of these strategies to ensure a variety of viewpoints are heard. It is also important to note that companies that are placing on the market in both the UK and EU will need to ensure that they follow the developments of these regimes closely to be able to remain compliant in the years to come.

WSP UK provides services that give clients easier access to market, increased reputation, and reduced reporting obligations, supporting manufacturers, downstream users, and producers of consumer products to help them meet their chemical and environmental obligations. If you want to understand what chemical policy changes will mean for your business, please get in contact

Jenny Butcher
Principal Consultant Product Stewardship

REACH@wsp.com   |  + 44 (0)1223 389680