GHS Implementation in United Kingdom

GB CLP and REACH Regulations - Post-Brexit Chemical Safety Framework

Overview

Following Brexit, the UK has implemented its own chemical safety framework based on EU CLP and REACH regulations. The GB CLP Regulation ensures continued GHS implementation while maintaining high standards of chemical safety and facilitating international trade.

Implementation Timeline

Regulatory Authorities

Health and Safety Executive (HSE)

  • GB CLP Regulation enforcement
  • Workplace chemical safety
  • Classification and labelling oversight
  • Market surveillance and compliance

Department for Environment, Food and Rural Affairs (DEFRA)

  • GB REACH implementation
  • Chemical registration oversight
  • Environmental protection policy
  • International cooperation

Environment Agency

  • Environmental enforcement
  • Chemical release monitoring
  • Pollution prevention
  • Waste management oversight

Regulatory Framework

Post-Brexit Legislation

The UK has retained EU chemical safety principles while developing its own regulatory framework to ensure continued protection and international alignment.

GB CLP Regulation

  • Scope: Classification, labelling and packaging of chemicals
  • Basis: Retained EU CLP with UK-specific amendments
  • Application: Great Britain (England, Scotland, Wales)
  • Enforcement: HSE and local authorities

GB REACH Regulation

  • Chemical registration and evaluation
  • Substance authorization and restriction
  • Chemical safety assessment requirements
  • Downstream user obligations

Control of Substances Hazardous to Health (COSHH)

  • Workplace exposure control
  • Risk assessment requirements
  • Health surveillance provisions
  • Training and information duties

Classification and Labelling Requirements

GB CLP Requirements

All substances and mixtures placed on the GB market must comply with GB CLP classification and labelling requirements.

Hazard Classes

  • Physical Hazards: 16 classes following GHS principles
  • Health Hazards: 10 classes including CMR substances
  • Environmental Hazards: 2 classes for aquatic environment
  • Additional Classes: Ozone layer depletion

Labelling Elements

  • Product Identifiers: Chemical name and identifiers
  • Hazard Pictograms: Standardized GHS symbols
  • Signal Words: "Danger" or "Warning"
  • Hazard Statements: H-codes in English
  • Precautionary Statements: P-codes for safe use
  • Supplier Information: UK company details

Post-Brexit Changes and Requirements

Key Changes from EU System

While maintaining GHS principles, the UK has introduced specific requirements for the post-Brexit regulatory landscape.

GB Classification and Labelling Inventory

  • Separate System: Independent from EU C&L Inventory
  • Notification Requirements: Substances ≥1 tonne/year
  • Timeline: Within one month of placing on GB market
  • HSE Portal: Online submission system

Poison Centres Notifications

  • UK UFI System: Unique Formula Identifiers for GB
  • NPIS Notifications: National Poisons Information Service
  • Scope: Hazardous mixtures for consumers/professionals
  • Format: IUCLID submission to HSE

Northern Ireland Protocol

Dual Regulatory System

Northern Ireland follows EU regulations for goods that may enter the EU market, creating a unique dual system.

Northern Ireland Arrangements

  • EU CLP Application: EU regulations continue to apply
  • ECHA Submissions: Continued use of EU systems
  • Market Access: Dual compliance for some products
  • Enforcement: HSE NI and EU coordination

Compliance and Enforcement

Enforcement Framework

HSE and local authorities enforce GB CLP requirements with significant penalties for non-compliance.

Enforcement Measures

  • Market Surveillance: Product compliance monitoring
  • Inspections: Workplace and facility audits
  • Improvement Notices: Mandatory corrective actions
  • Prohibition Notices: Immediate cessation orders
  • Prosecutions: Criminal proceedings for serious breaches

Penalty Structure

  • Summary Conviction: Up to £5,000 fine
  • Indictment: Unlimited fines
  • Imprisonment: Up to 2 years for serious offenses
  • Corporate Liability: Company director responsibilities

Resources and Support