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Classification, labelling and packaging (CLP): what GB-based businesses, supplying the GB market, need to do after the Transition Period ends

When the Transition Period ends on the 31st December 2020, the European Union Regulation for the Classification, Labelling and Packaging of substances and mixtures (EU CLP) will cease to apply in Great Britain (GB). From the 1st January 2021, the EU CLP Regulation will be replaced by the standalone GB Classification, Labelling and Packaging of substances and mixtures Regulation (GB CLP).  GB CLP will adopt the United Nations Globally Harmonized System of the classification and labelling of chemicals (UN GHS) in a similar way to EU CLP.  Once the Transition Period has ended, those CLP functions now carried out by ECHA and the European Commission will be carried out by HSE, with support from other government departments/agencies and the Welsh and Scottish Governments. Decisions will be taken by the Secretary of State with the consent of the Scottish and Welsh ministers. This means that GB-based businesses that supply the GB market with substances and mixtures will deal with HSE as the GB CLP Agency instead of ECHA.

The duties and obligations of GB-based businesses supplying the GB market include the following:

In addition, as under EU CLP, there are obligations on GB-based 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, labeling and packaging are fulfilled. From the 1st January 2021, suppliers must also comply with GB mandatory classification and labelling which replaces the EU harmonised classification and labelling (CLH) system in GB.

There are no changes to the requirements where CLP labelling may appear alongside those for transport. More information about transporting dangerous goods, including the transport  labelling requirements is available on GOV.UK.

There are no changes to the packaging requirements. The requirements for child resistant closures and tactile warning devices will remain in place.

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

The duty to notify substances placed directly on the GB market, either on their own or in a mixture, will apply to GB-based manufacturers and importers supplying the GB market. Notification will be made to HSE as the GB CLP Agency, rather than ECHA. Notification of certain substances will be exempt; further guidance on such exemptions is provided in the CLP scenario table.

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This page tells you what you will need to do for when the Transition Period ends. It will be updated if anything changes. Last updated 18/09/2020.

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Implications for business

A new website is currently under construction that will provide in-depth guidance on the new GB CLP regime. In the meantime, the following bullet points highlight the main changes under GB CLP:

More information

If you require further information, please contact the CLP helpdesk:

UK CLP Helpdesk - [email protected]

Scenario table to help you prepare

This scenario table sets out a number of actions and dates your business should be aware of to ensure you are prepared for the end of the Transition Period.

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Updated 2020-09-21