UK REACH and GB CLP: Chemical Regulation in Great Britain

Who it applies to

UK REACH and GB CLP apply to manufacturers, importers, downstream users and distributors who place chemicals on the market in Great Britain. A company in Great Britain that imports a substance from the EU becomes an importer under UK REACH, and an EU company exporting to Great Britain typically needs a GB-based importer or only representative. Northern Ireland follows EU REACH and EU CLP under its trading arrangements, so a business supplying all of the UK may have to meet two systems.

What they require for SDSs and labels

• UK REACH SDS. The duty to supply an SDS mirrors EU REACH Article 31, and the format follows an adapted version of the Annex II layout. The sheet must be in English and give the details of the GB supplier or responsible party.
• GB CLP classification. Suppliers must classify, label and package hazardous products using GB CLP criteria, which follow the GHS, with labels in English and the standard pictograms, signal words and statements.
• Mandatory classifications. GB has its own list of mandatory classifications and labelling (GB MCL), maintained by HSE, which replaces the EU's Annex VI for Great Britain. Entries are added through an HSE-led process and may differ from EU entries.
• Notification. GB CLP has its own notification arrangements, separate from ECHA's, and its poison-centre arrangements differ from the EU's harmonised system; check HSE guidance.
• Registration. UK REACH has its own registration, with transitional arrangements for companies that had EU registrations.

The details, timetables and fees change; check HSE's guidance for current requirements.

Key differences versus EU rules and OSHA HazCom

• Versus EU REACH/CLP. GB chemical law is a separate system. It started from the same text, but classification lists, registration, SVHC lists and some label details can now differ, so an EU label or sheet is not automatically a compliant GB one.
• Versus OSHA HazCom. Like the EU, GB includes environmental hazard classes, expects all 16 SDS sections, and has registration for substances. HazCom is narrower and workplace-focused. In GB, workplace use of chemicals is also regulated under COSHH, which requires employers to assess risks and control exposure using the SDS as an input.
• Workplace exposure limits. Great Britain publishes its own workplace exposure limits (EH40), which differ from OSHA PELs and EU limits; see reading exposure limits.

Practical points

• If you sell in Great Britain, have a GB-based supplier address on your label and SDS where required.
• Use the GB classification where one exists, and keep it consistent between label and sheet. See labeling requirements for the shared principle.
• If you sell in both Great Britain and the EU, check whether the classifications differ and whether you need separate sheets.
• For the EU side, see EU REACH, EU CLP and REACH Annex II.

Worked scenario: selling to both Great Britain and Ireland

A formulator in Dublin supplies customers in both the Republic of Ireland and England. The EU CLP label and EU Annex II sheet work for Ireland. For Great Britain, the label must follow GB CLP and carry the details of a GB-based responsible party, and the SDS must meet UK REACH requirements and be in English with GB contacts. Where GB's mandatory classification differs from the EU harmonised classification, the GB label has to follow the GB list. The simplest approach for the formulator is often to maintain two label and SDS versions from one underlying classification dataset.

Frequently asked questions