The Control of Mercury (Amendment) Regulations 2025
The Regulations amended Part A of Annex 2 to Regulation (EU) 2017/852 by inserting new entries and associated phase-out dates for mercury use in several categories of devices, effective from December 23rd, 2025, across England, Wales, and Scotland.
The Secretary of State made The Control of Mercury (Amendment) Regulations 2025, obtaining consent from the Welsh and Scottish Ministers, to amend Part A of Annex 2 of Regulation (EU) 2017/852 on mercury.
These Regulations, which extend to England, Wales, and Scotland, introduce specific amendments to phase-out dates for mercury content in various products, including certain lighting types, sensing devices, and electronic components, aligning UK law with recent decisions made by the Conference of the Parties to the Minamata Convention on Mercury.
Arguments For
Updates UK domestic legislation concerning mercury use to align with international obligations under the Minamata Convention on Mercury, ensuring continued environmental protection compliance.
Introduces revised deadlines for phasing out mercury in specific electrical, electronic, and measurement equipment, providing clarity and certainty for manufacturers and users regarding compliance timelines.
Incorporates specific decisions (MC-4/3 and MC-5/4) from the Conference of the Parties to the Minamata Convention, reflecting ongoing international efforts to control mercury pollution.
Amends specific Annex 2 entries for items like fluorescent lamps (CFLs and LFLs), measurement bridges, and specialized sensors, detailing permitted exemptions or new cessation dates.
Arguments Against
Introduces various new phase-out deadlines (e.g., 2025, 2026, 2027) for specific mercury-containing products, potentially creating short-term supply chain disruption or increased costs for businesses needing to transition to alternatives.
The exclusion of certain equipment from the amendments (e.g., R&D uses, high-precision instruments lacking alternatives) might be perceived as insufficient or not comprehensive enough in eliminating mercury use immediately.
Extending the regulatory reach requires compliance from entities in England, Wales, and Scotland, necessitating coordination across devolved administrations, despite the consent mechanism noted in the preamble.
The document relies on decisions adopted under an international convention and EU regulation framework, which may complicate regulatory interpretation following Brexit.
The Secretary of State makes these Regulations in exercise of the powers conferred by Article 20(1) of Regulation (EU) 2017/852 of the European Parliament and of the Council of 17 May 2017 on mercury1.
In accordance with Article 21(8) of that Regulation, the Secretary of State makes these Regulations with the consent of the Welsh Ministers and the Scottish Ministers.
The designated Secretary of State created these Regulations by utilizing the authority granted under Article 20(1) of the EU Regulation 2017/852 concerning mercury.
Furthermore, the Secretary of State enacted these rules only after securing the necessary consent from both the Welsh Ministers and the Scottish Ministers, as required by Article 21(8) of the same Regulation.
Citation, commencement and extent 1. (1) These Regulations may be cited as the Control of Mercury (Amendment) Regulations 2025.
(2) These Regulations come into force on 23rd December 2025.
(3) These Regulations extend to England and Wales and Scotland.
The official citation for this statutory instrument is The Control of Mercury (Amendment) Regulations 2025.
The regulations became legally effective on December 23rd, 2025.
The geographical scope of these regulations covers England, Wales, and Scotland.
Amendment of Part A of Annex 2 to Regulation (EU) 2017/852 2. (1) Part A of Annex 2 to Regulation (EU) 2017/852 of the European Parliament and of the Council of 17 May 2017 on mercury is amended as follows.
This part specifies that modifications will be made to Part A of Annex 2, which is part of the existing EU Regulation 2017/852 concerning mercury.
(2) In the
“2A. Very high accuracy capacitance and loss measurement bridges and high frequency radio frequency switches and relays in monitoring and control instruments with a maximum mercury content of 20 mg per bridge, switch or relay, except those used for research and development purposes.
31.12.2025”.
A new entry, numbered 2A, is added immediately after existing entry 2 in Annex 2.
This new entry permits the use of specific high-accuracy measurement bridges, switches, and relays containing up to 20 mg of mercury in monitoring and control instruments, setting a phase-out date of December 31, 2025.
An exception applies only to equipment used for research and development purposes.
(3) In the
“3A. CFLs for general lighting purposes: CFL.i ≤ 30 watts not covered by entry 3, point (a).
31.12.2025
3B. The following CFLs for general lighting purposes:
- (a)
CFL.ni ≤ 30 watts not covered by entry 3, point (b);
- (b)
CFL.i > 30 watts;
- (c)
CFL.ni > 30 watts.
31.12.2026”.
New entries 3A and 3B are inserted following entry 3, addressing Compact Fluorescent Lamps (CFLs) used for general lighting.
Entry 3A sets a phase-out date of December 31, 2025, for specific low-wattage CFLs.
Entry 3B mandates a later phase-out date of December 31, 2026, for other categories of CFLs, including those with higher wattages and specialized types (CFL.ni).
(4) In the
“4A. LFLs for general lighting purposes: triband phosphor not covered by entry 4, point (a).
31.12.2027
4B. LFLs for general lighting purposes: halophosphate phosphor not covered by entry 4, point (b).
31.12.2026
4C. Non-linear fluorescent lamps (NFLs) (e.g. U-bend or circular) for general lighting purposes: halophosphate phosphor.
31.12.2026
4D. NFLs for general lighting purposes: triband phosphor.
31.12.2027”.
Four new entries, 4A through 4D, are added after entry 4, focusing on Linear Fluorescent Lamps (LFLs) and Non-linear Fluorescent Lamps (NFLs) for general lighting.
Phase-out deadlines vary: December 31, 2026, applies to halophosphate phosphor LFLs and NFLs, while December 31, 2027, applies to triband phosphor LFLs and NFLs.
(5) In the
“6A. CCFLs and EEFLs for electronic displays not covered by any of points (a) to (c) of entry 6.
31.12.2025”.
Entry 6A is inserted after entry 6, setting a deadline of December 31, 2025, for phasing out Cold Cathode Fluorescent Lamps (CCFLs) and External Electrode Fluorescent Lamps (EEFLs) used in electronic displays, provided they are not already covered under existing points (a) to (c) of entry 6.
(6) In the
“10. Strain gauges to be used in or with plethysmographs and not covered by entry 9, point (f).
31.12.2025
11. The following electrical and electronic measuring devices:
- (a)
melt pressure transducers;
- (b)
melt pressure transmitters;
- (c)
melt pressure sensors.
This entry does not cover devices installed in large-scale equipment or used for high precision measurement, where no suitable mercury-free alternative is available.
31.12.2025
12. Mercury vacuum pumps.
31.12.2025
13. Tyre balancers and wheel weights.
31.12.2025
14. Photographic film and paper.
31.12.2025
15. Propellant for satellites and spacecraft.
31.12.2025”.
Several new items, numbered 10 through 15, are added after entry 9, with all specified phase-out dates set to December 31, 2025.
These additions cover specific strain gauges used with plethysmographs, various melt pressure devices (transducers, transmitters, sensors), mercury vacuum pumps, tyre balancers, wheel weights, photographic film/paper, and propellant for spacecraft.
The melt pressure device exemption specifically excludes those in large-scale equipment or used for high-precision measurement where no mercury-free alternative exists.
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