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Classification, labelling and packaging (CLP) what you’ll need to do in a no-deal scenario

If the UK leaves the European Union (EU) with no deal, the UK would establish an independent standalone chemicals regime.

At the time of exit, as the UK would effectively adopt the United Nations Globally Harmonised System (UN GHS) in the same way as the EU.

The UK classification and labelling regime would be based on the existing EU regulatory regime to provide continuity for businesses.

Functions now carried out by the EU (including those performed by ECHA), will be carried out in the UK by HSE. This would mean companies operating in the UK dealing with HSE in place of ECHA.

The majority of CLP would continue to be applied in the UK, so the main duties and obligations on UK manufacturers, importers and downstream users to classify, label and package the substances and mixtures they place on the UK market will remain. This would also be the case for the obligations on those suppliers to identify, examine and evaluate available scientific and information on substances and mixtures where it relates to the possible physical, health or environmental hazardous properties of those chemicals to ensure all the requirements of classification are fulfilled. Suppliers must also comply with mandatory classification and labelling.

All labelling requirements would remain in place including the principles of precedence for the different labelling elements, the location of the label on packaging, and exemptions where available. Our existing guidance provides an overview of CLP labelling and packaging.

There are no changes to the requirements where CLP (supply) labelling appears alongside transport labelling. More information about transporting dangerous goods, including transport labelling requirements is available on GOV.UK.

Packaging requirements stay the same, including those for child resistant closures and tactile warning devices.

Testing arrangements, including the prohibition of testing on humans or primates for the purposes of CLP, will still apply.

Manufacturers’ and importers’ duty to notify the required classification and labelling of the substances that they place on the UK market will continue. These notifications will be made to HSE, rather than European Chemicals Agency (ECHA).

Implications for business

Existing arrangements would continue to apply, with the following changes:

More information

More information is available on our existing CLP guidance pages

Scenario table to help you prepare

This scenario table sets out a number of actions and dates that your company would need to investigate so that you can prepare for a ‘no-deal’ scenario.

Updated 2019-09-06