The UK is seeking‘ dynamic alignment’ with the EU on biocides
EU Sanitary & Phytosanitary( SPS) agreement, building on commitments made in May 2025.4 During the Lords debate on 27 April, Baroness Sherlock confirmed that the Government intended to pursue dynamic alignment with the EU for biocides, indicating that this would supersede the previous domestic reform proposals.
This raises important questions about the future of the reforms outlined in the February 2026 consultation response, and signals a potentially fundamental change in direction. Rather than developing a bespoke GB regulatory framework that selectively recognises EU decisions, the government could move towards much closer alignment with EU BPR.
Consequently, proposals such as recognising overseas active substance approvals, introducing risk-based renewal deadlines and expanding domestic regulatory flexibility may need to be reconsidered. However, the extent to which individual reforms will be retained, modified or abandoned remains unclear.
This is a genuinely different destination from the one most of us had been planning around. For industry, closer alignment could reduce regulatory duplication and address some of the divergence that has developed since January 2021.
However, what happens to active substances and products already subjected to divergent GB and EU assessments?
In some cases, the HSE has adopted different assessment approaches, requested additional data or reached different conclusions from EU competent authorities, requiring applicants to undertake further work and incur substantial costs. It remains unclear whether these differences would be revisited, whether EU conclusions could be adopted for applications already in progress or whether applicants would still need to satisfy outstanding GBspecific requirements.
Without clear transitional provisions, businesses could therefore remain subject to the consequences of historic regulatory divergence even as the two systems move towards closer alignment. Furthermore, dynamic alignment would not necessarily mean automatic mutual recognition of existing authorisations or resolve the substantial assessment backlogs affecting either programme.
While the government has identified biocides as falling within the intended scope of the SPS agreement, its final terms, implementation arrangements and practical consequences remain subject to negotiation. Dynamic
alignment should therefore be regarded as the stated direction of travel rather than a confirmed regulatory outcome. Nevertheless, the future of GB BPR may now be shaped as much by wider UK – EU negotiations as by the domestic reforms on which industry was consulted earlier this year.
Further uncertainty, no acceleration yet
Regulatory timelines remain uncertain. The UK – EU SPS agreement was initially expected to be concluded during summer 2026, with implementation targeted for mid-2027. Negotiations have since extended beyond the original timetable, with the government now aiming to reach an agreement by the end of 2026. The implementation date and transitional arrangements remain subject to negotiation.
Separately, the government intends to introduce secondary legislation by June 2027 to incorporate the six additional EU hazard classes into GB CLP. This is being progressed independently of the 2026 chemicals statutory instrument and remains a separate legislative workstream from GB BPR.
Meanwhile, several of the questions I raised back in May remain unresolved. The temporary extensions to HSE’ s product application processing
22 SPECIALITY CHEMICALS MAGAZINE ESTABLISHED 1981