The UK Health and Safety Executive (HSE) has updated the chemicals list under the GB Prior Informed Consent (GB PIC) Regulation, introducing additional controls on hazardous chemical exports from Great Britain.
The amendments, announced on 27 August 2026 and effective from 28 August 2026, expand PIC requirements for several chemicals and introduce additional export prohibitions covering certain Persistent Organic Pollutants (POPs) and mercury-containing products.
The GB PIC regime regulates the import and export of certain hazardous chemicals that are banned or severely restricted in Great Britain. HSE acts as the Designated National Authority for the GB PIC system and administers the export notification framework. (HSE)
What Is the GB Prior Informed Consent Regulation?
The GB Prior Informed Consent Regulation establishes controls for the export and import of certain hazardous chemicals from and into Great Britain.
The GB PIC chemicals list is divided into five parts, with different regulatory requirements applying to each category:
- Part 1: Chemicals subject to export notification
- Part 2: Chemicals requiring export notification and, in addition, importing-country consent
- Part 3: Chemicals listed in Annex III of the Rotterdam Convention and subject to the international PIC procedure
- Part 4: Persistent Organic Pollutants subject to an export ban
- Part 5: Other chemicals or products subject to export prohibition
The distinction is particularly important for exporters because the applicable obligations depend on where a substance is listed.
New Chemicals Added to Part 3 of the GB PIC List
Several substances listed in Annex III of the Rotterdam Convention have been added to Part 3 of the updated GB PIC chemicals list.
These include:
- Decabromodiphenyl ether (DecaBDE)
- Perfluorooctanoic acid (PFOA), its salts and related compounds
- Terbufos
- Carbosulfan
- Fenthion ultra-low volume formulation, with active ingredient ≥640 g/L
Chemicals listed in Part 3 are subject to the applicable export notification requirements and the Prior Informed Consent procedure under the Rotterdam Convention.
Depending on the applicable importing-country decision, exporters may therefore need to obtain explicit consent before shipment.
Existing Carbosulfan and Fenthion entries in Part 2 are also being removed following their inclusion in Part 3.
Export Prohibitions Expanded for Persistent Organic Pollutants
A number of Persistent Organic Pollutants have also been added to Part 4 of the GB PIC list to reflect international controls under the Stockholm Convention.
The newly covered substances include:
- Dicofol
- Pentachlorophenol (PCP), its salts and esters
- PFOA, its salts and related compounds
- PFOS, its salts and related compounds
- PFHxS, its salts and related compounds
- Methoxychlor and its isomers
Chemicals listed in Part 4 are generally prohibited from export from Great Britain, subject to any specific exemptions or derogations provided under the relevant legislation.
DecaBDE and PFOA have also been included in Part 1 because their uses are severely restricted.
PFAS Substances Face Increasing Export Controls
The update is particularly significant for companies handling PFAS substances, including PFOA, PFOS and PFHxS.
These substances are subject to increasing international and national regulatory scrutiny because of their persistence in the environment and associated environmental and health concerns.
Businesses exporting chemicals, mixtures or articles containing these substances should therefore determine not only whether a PFAS is present, but also its concentration, intended use and whether any applicable exemption or derogation is available.
New Export Restrictions for Mercury-Containing Products
Following changes to UK mercury legislation, a broad range of mercury-containing products has been added to Part 5 of the GB PIC list.
Affected product categories include:
- certain Compact Fluorescent Lamps;
- certain Cold Cathode Fluorescent Lamps (CCFLs);
- certain External Electrode Fluorescent Lamps (EEFLs);
- certain switches and relays;
- mercury-containing cosmetic products;
- mercury-containing pesticides;
- mercury-containing biocidal products;
- non-electronic measuring devices containing mercury;
- electronic measuring devices containing mercury;
- certain vacuum pumps;
- tyre balancing weights;
- certain photographic films and papers; and
- certain satellite propellant systems.
Depending on the product and intended use, exports from Great Britain may now be prohibited.
Are Any Exemptions Available for Mercury-Containing Products?
Certain exemptions may remain available for specific applications.
These may include:
- civil defence and military uses;
- research activities;
- calibration;
- reference standards; and
- certain replacement components.
For replacement parts, additional conditions may apply, including demonstrating that no technically feasible mercury-free alternative is available.
Businesses should therefore assess both the product category and its specific intended use before determining whether an export prohibition applies.
What Are the Main GB PIC Obligations for Exporters?
Compliance obligations under GB PIC depend on the part of the chemicals list in which the relevant substance is included.
Requirements may include:
- submitting an export notification;
- obtaining explicit consent from the importing country;
- assessing concentrations in mixtures and articles;
- reviewing permitted uses and exemptions;
- determining whether an export prohibition applies; and
- completing annual reporting obligations.
HSE requires companies exporting or importing GB PIC-listed chemicals to report quantities from the previous calendar year by 31 March each year.
What Does the GB PIC Update Mean for Businesses?
The amendments effective from 28 August 2026 mean that companies exporting chemicals, mixtures or relevant products from Great Britain should reassess their portfolios against the updated GB PIC chemicals list before shipment.
Businesses should:
- identify whether products contain substances listed under GB PIC;
- determine whether the substance is included in Part 1, 2, 3, 4 or 5;
- review applicable concentration thresholds and intended uses;
- determine whether export notification is required;
- verify whether importing-country consent is necessary;
- assess whether a POP or mercury-containing product is subject to an outright export prohibition; and
- review any exemptions or derogations before export.
Companies handling PFOA, PFOS, PFHxS, DecaBDE, POPs or mercury-containing products should pay particular attention to the updated requirements and ensure that compliance checks take place before relevant shipments leave Great Britain.