Since Brexit, chemical labelling rules in the UK have moved away from the EU system, but compliance demands have not relaxed. Businesses selling chemical products in Great Britain must now follow the retained version of the Classification, Labelling and Packaging (CLP) Regulation. While many requirements remain similar to EU standards, several UK-specific changes apply, and suppliers need to stay alert to avoid enforcement action.
UK CLP Regulation After Brexit
The retained CLP Regulation became law in Great Britain from 1 January 2021. It is based on the EU’s original Regulation (EC) No 1272/2008 but has been adapted for the domestic market. Products supplied in England, Scotland, and Wales must comply with UK CLP rules, while Northern Ireland follows the EU CLP Regulation under the terms of the Northern Ireland Protocol. This split means businesses trading across the UK and EU must often meet both sets of requirements.
UK CLP applies to substances and mixtures classified as hazardous. It dictates how hazards must be communicated through standardised pictograms, signal words, hazard statements, and precautionary statements. The UK Government has retained the Globally Harmonised System (GHS) framework, currently aligned with GHS Revision 7, though this may diverge in future updates.
Labelling Requirements for Great Britain
Chemical labels in Great Britain must display the correct product identifiers, supplier details, hazard pictograms, signal words, and appropriate hazard and precautionary statements. Labels must be clear, indelible, and in English. The supplier address must be a UK address, as EU addresses no longer meet the legal requirement for identification under UK CLP.
Products placed on the GB market also require notification to the UK’s Classification and Labelling Inventory, held by the Health and Safety Executive (HSE), rather than the EU’s European Chemicals Agency (ECHA). This notification process is mandatory for manufacturers, importers, and certain downstream users placing hazardous chemicals on the GB market.
Key Differences for UK Suppliers
While much of the technical content remains the same, UK suppliers must be aware of practical differences. The UK now has its own version of Annex VI, containing a list of mandatory classifications. Future updates to GB mandatory classifications are managed by the HSE, which may lead to differences from EU harmonised classifications.
Another key point involves imports. Chemical products imported from the EU to Great Britain are now classed as ‘imports’ rather than ‘intra-community trade.’ This change affects the duties of UK importers, who must take on full responsibility for classification, labelling, and notification, even when products were already labelled for the EU market.
Summary
Post-Brexit, chemical suppliers in Great Britain must follow UK CLP rules, maintain a UK supplier address, and notify the HSE about hazardous products. With separate systems operating in Northern Ireland and the EU, chemical businesses must track changes on both sides to avoid compliance failures.