In a significant regulatory development, the UK Government has begun taking formal steps to align chemical labelling laws between Northern Ireland and Great Britain, addressing long-standing concerns from businesses navigating post-Brexit trading rules. This move marks a major shift in how hazardous chemicals are classified and labelled across the UK, and it aims to simplify processes for manufacturers, importers, and distributors who operate across regional borders.
Since the UK’s departure from the European Union, chemical regulations have been a complex area—particularly due to the Northern Ireland Protocol, which kept Northern Ireland aligned with many aspects of EU law to avoid a hard border with the Republic of Ireland. As a result, companies dealing with chemical substances faced a dual regulatory system. Northern Ireland remained subject to the EU’s CLP Regulation (Classification, Labelling and Packaging of substances and mixtures), while Great Britain began operating under its own version—GB CLP—administered by the UK’s Health and Safety Executive.
This regulatory divergence led to confusion, duplicated efforts, and increased compliance costs for businesses. For instance, companies supplying chemicals across both regions were required to navigate two separate classification frameworks, maintain two sets of labelling, and in some cases reformulate safety documentation depending on where the product would be sold. The practical burden of maintaining compliance with both GB and EU requirements strained small and medium-sized enterprises in particular.
Recognising the challenges, the UK Government has signalled its intention to streamline this regulatory landscape by moving toward a more consistent chemical classification system across the UK. This includes efforts to ensure that substances placed on the market in both Northern Ireland and Great Britain can follow a unified labelling approach, minimising duplication and reducing the administrative overhead for industry.
To facilitate this alignment, discussions have been ongoing between the UK Government and devolved administrations, alongside consultations with key stakeholders in the chemical sector. The goal is to reduce regulatory friction while continuing to uphold high standards of safety, environmental protection, and public health. The Health and Safety Executive, which oversees GB CLP, has also indicated its willingness to consider scientific opinions and classifications issued by the European Chemicals Agency, where appropriate, as part of the alignment process.
The move is seen as a positive step by many in the industry, who have long called for a more pragmatic approach that balances regulatory autonomy with practical consistency. It also signals a broader shift in the UK’s post-Brexit regulatory strategy, suggesting a willingness to ease trade-related pressures in specific sectors without undermining core legal frameworks.
While full alignment will take time and may require further legislative amendments, the direction of travel is clear. Businesses can expect more clarity and predictability in the months ahead, with transitional support likely to be made available as changes are phased in. For now, the Government’s actions offer a welcome sign that common-sense adjustments are being made to support both regulatory integrity and economic functionality across all parts of the UK.
