GB biocides reform: A new direction emerges
Lauren Hypson, biocides regulatory manager at Barkwith Associates, looks at what dynamic alignment between the EU and Great Britain may actually mean
Back in May, I delivered a presentation at the Biocides Symposium on the GB regulatory landscape and the Health & Safety Executive( HSE)’ s proposed chemical legislative reforms. At the time, industry faced numerous challenges: an increasingly delayed active substance review programme, uncertainty surrounding transitional arrangements under the Control of Pesticides Regulations( COPR) and ambitious reform proposals without a confirmed implementation timetable.
Four months on, the regulatory landscape has shifted considerably. While some immediate legislative changes have provided much-needed continuity, the government’ s proposed move towards dynamic alignment with the EU could fundamentally reshape the future of biocides regulation in Great Britain( GB, meaning England, Scotland and Wales), potentially superseding the domestic reforms discussed earlier.
The question now is what this change in direction means for industry, particularly for businesses already navigating regulatory divergence, prolonged assessment delays and increasingly uncertain routes to market.
The situation in May
To understand why this shift matters, it is worth revisiting the regulatory position. When the GB Biocidal Products Regulation( BPR) became a legally separate regime on 1 January 2021, GB inherited the significant delays already affecting the EU active substance review programme. While both programmes have been extended to December 2030, the GB programme has fallen progressively further behind its EU counterpart.
For products containing active substances still awaiting approval, businesses have continued to rely on the COPR, where applicable, to maintain market access. With assessment backlogs persisting and uncertainty surrounding the current regulatory landscape, some applicants have sought to extend or obtain market access by introducing an additional active substance that remains under review.
This is often driven by commercial necessity rather than unwillingness to comply. Maintaining revenue from existing products helps businesses finance the substantial costs of dossier preparation, testing and postsubmission dossier support.
The GB regulatory landscape on biocides has changed considerably in recent month
Historically, COPR has operated largely as a precedent-based system, allowing products comparable to existing approvals to follow the relatively straightforward secretariat route. However, in late 2025, we encountered increasing scrutiny from the HSE for some of our clients’ products, with additional technical justifications requested even where established safety and efficacy precedents existed.
The agency’ s recently updated guidance confirms that further information may be required, particularly for products containing multiple active substances or where the function of individual ingredients requires clarification. 1 In our experience, providing these justifications has not always resolved
20 SPECIALITY CHEMICALS MAGAZINE