HSE Consultation: Six Substances Proposed for the UK REACH Candidate List — Deadline 20 August

This is more immediate for your compliance work than the PFAS firefighting-foam story we’ve been tracking. HSE currently has multiple substances under consultation for addition to the UK REACH Candidate List, and responses are due by 23:59 on 20 August. Unlike a general policy update, this one has a hard deadline and a direct route to new Article 33 duties — it’s worth acting on now, not filing for later.

The substances under consultation

• Medium-Chain Chlorinated Paraffins (MCCPs)
• O,O,O-triphenyl phosphorothioate (TPPT) — proposed on PBT (persistent, bioaccumulative and toxic) grounds
• OAPP — proposed on vPvB (very persistent, very bioaccumulative) grounds
• Bis(4-chlorophenyl)sulphone (BCPS) — proposed on vPvB grounds
• Bumetrizole
• Perfluoroheptanoic acid (PFHpA) and its salts — another PFAS entering the UK Candidate List pipeline

That last one matters on its own: it’s a reminder that PFAS additions aren’t a one-off event tied to a single announcement, but an ongoing stream of individual substances working through consultation, each on its own timeline.

How the consultation actually works

This is the part that catches people out. If HSE receives no comments on a proposal, the substance is added to the Candidate List — consultation silence isn’t a safe outcome, it’s the default path to listing. Where comments are received, HSE must consider them and reach a decision on inclusion within 45 days of the consultation closing. Either way, every substance on this list is on a fairly short, defined path to a Candidate List decision from here.

Why this is more urgent than it looks

General PFAS commentary tends to describe direction of travel rather than a specific date. This consultation is different: there’s a fixed deadline, a defined set of named substances, and a clear mechanical process behind what happens next. For defence supply chains in particular — where MCCPs, phosphorothioates and PFAS-related substances turn up in lubricants, flame retardants, plasticisers and specialty coatings — this is exactly the kind of update worth flagging to clients directly, rather than folding into a general PFAS watch note.

What to do before 20 August

• Search BOMs, safety data sheets and supplier declarations for these six substances by name, and confirm the CAS/EC identifiers with your suppliers where they’re not already on file.
• Flag any confirmed or suspected presence to your technical or regulatory team now, so there’s a documented starting position before any of these substances are actually listed.
• If any of these substances are material to your product range, consider whether a consultation response is worth submitting directly, rather than relying on the default outcome.
• Set a calendar reminder for the consultation close and the 45-day decision window that follows, so you’re not caught off guard by a listing decision landing without warning.

If any of these substances are confirmed present in an article above 0.1% weight by weight once added to the Candidate List, Article 33 communication duties apply from the listing date — not from whenever you next happen to review your declarations.

How we can help

We’re already screening client BOMs and supplier declarations against this exact consultation list, prioritising defence supply chains where these substance classes show up most. If you’d like us to check your product range against these six substances before the 20 August deadline, get in touch.

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