Introduction to GB CLP and SDS Requirements

UK has officially left EU since 1 Jan. 2021. Following the UK's exit from the EU, the CLP Regulation has been retained in GB law, with some minor changes, to become the GB CLP Regulation. In this article, CIRS will give an introduction to the classification and labeling of chemicals in GB as well as the SDS requirements, and provide compliance suggestions to related enterprises.

What is GB CLP?

The GB CLP Regulation adopts the United Nations' Globally Harmonized System of the classification and labeling of chemicals (GHS) and it is prepared based on the EU CLP.

The GB CLP regulation has already taken effect. In accordance with the requirements of GB CLP, from 1 Jan. 2021, chemicals or mixtures that put in GB market shall have classification and label.

The GB CLP applies in England, Scotland and Wales (GB). However, in Northern Ireland, EU CLP still applies.

What are the differences between EU CLP and GB CLP?

The EU CLP Regulation will be retained in GB law as retained EU law. But there are still some minor changes in order for GB CLP to operate fully and effectively in Great Britain. Details are as follows:

1. The GB CLP Regulation applies to NI based manufacturers, downstream users and distributors (collectively referred to as 'NI suppliers') who directly supply the GB market with substances and mixtures;
2. Under GB CLP Regulation, GB-based manufacturers and importers and NI suppliers directly supplying the GB market with new substances will have to notify HSE (Health and Safety Execution) within one month of placing 'new' substances on the GB market unless one of the exemptions applies;
3. Under GB CLP Regulation, all existing EU harmonised classification and labeling in force on 31 December 2020, are retained in Great Britain as GB mandatory classification and labeling (GB MCL);
4. Under GB CLP Regulation, the classification and labeling of substances and mixtures placed on the GB market must comply with GB MCL requirements;
5. Under GB CLP Regulation, GB-based importers or downstream users and NI-based distributors should also pay attention to the SDS and toxic information submission requirements;

Preparation and Communication of SDS under UK REACH

Safety Data Sheets (SDS) are required by the UK REACH Regulation. SDS is one of the most important documents in the safe supply, handling and use of chemicals that must be communicated throughout the supply chain. The requirements for SDS under UK REACH are the same as that under EU REACH. Defra (Department for Environment Food & Rural Affairs) has the lead responsibility for SDS.

It is worth mentioning that the SDS format requirements under EU REACH Annex II that are updated after UK exit from EU do not apply in GB.

CIRS Suggestions

Currently, the classification rules, mandatory classification list as well as the format of SDS under GB CLP and EU CLP are highly consistent. However, as time goes on, there may be some amendments to these regulations and the classifications of the same substances/mixtures may be different.

It is suggested that related enterprises should pay close attention to the regulation updates in EU and GB, and regularly update the SDS and labels.

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Further Information

The GB CLP Regulation