Classify and label chemicals for the GB market

If you manufacture, import, or supply chemicals in Great Britain (England, Scotland, and Wales), you must classify, label, and package them according to the GB CLP Regulation. This applies to hazardous substances and mixtures placed on the GB market.

CLP stands for Classification, Labelling and Packaging. The GB CLP Regulation is the UK version of the EU CLP Regulation, which was retained in UK law after Brexit. It uses the Globally Harmonised System (GHS) for hazard communication.

Who needs to comply with GB CLP

You must comply with GB CLP if you:

• Manufacture hazardous substances or mixtures in Great Britain
• Import hazardous substances or mixtures into Great Britain from any country (including the EU)
• Supply hazardous substances or mixtures to customers in Great Britain (as a distributor or retailer)
• Formulate mixtures using hazardous substances

Northern Ireland: Different rules apply in Northern Ireland under the Windsor Framework. Chemicals placed on the Northern Ireland market must comply with EU CLP. If you supply to both GB and NI, you may need to meet both sets of requirements.

Downstream users: If you only use chemicals at your workplace (rather than supplying them), you do not need to classify and label them yourself. However, you must use them safely and follow the information provided by your suppliers.

Classification requirements

Classification is the process of identifying the hazards of a chemical and assigning hazard categories. You must self-classify all hazardous substances and mixtures before placing them on the GB market.

Key requirements:

How to classify your chemicals

To classify a substance or mixture, you must:

1. Gather hazard data - Collect information about physical, health, and environmental hazards from test data, scientific literature, and reliable sources
2. Apply classification criteria - Compare your data against the classification criteria in Annex I of GB CLP for each hazard class
3. Assign hazard categories - Determine the severity category for each identified hazard
4. Identify hazard statements - Select the appropriate H-codes (hazard statements) for each hazard class and category

Mixtures: For mixtures, you can use test data on the mixture itself, or apply calculation methods using data on the individual ingredients (bridging principles).

Harmonised classifications: Some substances have mandatory harmonised classifications listed in Annex VI of GB CLP. You must use these classifications and may add further self-classifications for hazards not covered.

Classification records

You must keep records of your classification decisions for at least 10 years after you last supplied the substance or mixture. Records should include:

• The data sources used
• How you applied the classification criteria
• Any expert judgements made
• Date of classification and any updates

Labelling requirements

Once classified, you must label hazardous chemicals with specific information to warn users of the hazards. Labels must be in English for the GB market.

Mandatory label elements

Every label for a hazardous substance or mixture must include:

• Product identifier - Chemical name (for substances) or trade name plus hazardous ingredients (for mixtures)
• Supplier identification - Name, address, and telephone number of the GB-based supplier
• Nominal quantity - The amount of product in the packaging
• GHS hazard pictograms - Red-bordered diamond symbols showing the hazard type
• Signal word - Either "Danger" (for more severe hazards) or "Warning" (for less severe hazards)
• Hazard statements (H-codes) - Standardised phrases describing the nature of the hazard
• Precautionary statements (P-codes) - Standardised phrases describing recommended measures to minimise harm
• Supplemental information - Any additional hazard information required by GB CLP

The 9 GHS pictograms

GB CLP uses 9 standard hazard pictograms:

1. Exploding bomb - Explosives, self-reactive substances
2. Flame - Flammable gases, liquids, solids, aerosols
3. Flame over circle - Oxidising gases, liquids, solids
4. Gas cylinder - Gases under pressure
5. Corrosion - Corrosive to metals, skin corrosion, serious eye damage
6. Skull and crossbones - Acute toxicity (severe)
7. Exclamation mark - Lower-level health hazards (irritation, sensitisation)
8. Health hazard - Serious long-term health effects (carcinogenicity, mutagenicity)
9. Environment - Hazardous to the aquatic environment

Small packaging exemptions

Reduced labelling is permitted for packaging under 125ml. You may omit certain precautionary statements and some label elements, but hazard pictograms, signal words, and hazard statements must still appear.

Outer packaging

If hazardous chemicals are packed in an outer package, the outer packaging must also be labelled unless the inner packaging is clearly visible and complies with labelling requirements.

Safety Data Sheet requirements

You must provide a Safety Data Sheet (SDS) for hazardous substances and mixtures supplied to professional users. The SDS gives detailed information about hazards and safe handling.

When an SDS is required

You must supply an SDS if:

• The substance or mixture is classified as hazardous under GB CLP
• The substance is persistent, bioaccumulative and toxic (PBT) or very persistent and very bioaccumulative (vPvB)
• The substance is on the UK REACH Candidate List
• A mixture contains certain hazardous substances above specified concentrations

SDS format

Safety Data Sheets must follow the 16-section format specified in Annex II of UK REACH:

1. Identification of the substance/mixture and supplier
2. Hazards identification
3. Composition/information on ingredients
4. First-aid measures
5. Fire-fighting measures
6. Accidental release measures
7. Handling and storage
8. Exposure controls/personal protection
9. Physical and chemical properties
10. Stability and reactivity
11. Toxicological information
12. Ecological information
13. Disposal considerations
14. Transport information
15. Regulatory information
16. Other information

The SDS must be in English and provided free of charge. You must update it promptly when new hazard information becomes available.

Extended SDS

For substances registered under UK REACH at 10 tonnes or more per year, you may need to provide an extended SDS that includes exposure scenarios describing safe use conditions.

Poison centre notification

Before placing a hazardous mixture on the GB market, you must submit information to the National Poisons Information Service (NPIS) to help with emergency medical treatment.

Who must notify

Importers and downstream users who place hazardous mixtures on the GB market must submit poison centre notifications. This includes mixtures classified for:

• Health hazards (acute toxicity, skin/eye damage, sensitisation, etc.)
• Physical hazards (where relevant for emergency response)

Unique Formula Identifier (UFI)

You must generate a Unique Formula Identifier (UFI) for each mixture formulation. The UFI is a 16-character code that links your mixture to the poison centre notification. It must appear on the label.

UFIs are generated using free software available from HSE. Each distinct formulation requires its own UFI, though minor variations within defined limits may share a UFI.

How to submit notifications

Submit notifications to NPIS using IUCLID software. The notification must include:

• UFI
• Product identifier and trade names
• Full composition (ingredient identities and concentrations)
• Classification information
• Toxicological information
• Packaging types and sizes
• Product categories (consumer, professional, industrial)

Composition information submitted to NPIS is treated as confidential and used only for emergency response purposes.

Notification deadlines

You must notify before first placing the mixture on the market. Update notifications within a reasonable time when:

• The composition changes beyond defined tolerance limits
• Classification changes
• New toxicological information becomes available
• Product identifiers or UFI change

Penalties and enforcement

The Health and Safety Executive (HSE) enforces GB CLP requirements. Non-compliance can result in serious penalties.

Enforcement powers

HSE inspectors can:

• Enter premises and inspect products and documentation
• Take samples for analysis
• Issue improvement notices requiring corrective action
• Issue prohibition notices stopping supply of non-compliant products
• Prosecute for serious breaches

Penalties

Breaches of GB CLP can result in:

• Unlimited fines for corporate offenders
• Imprisonment for individuals responsible for serious breaches
• Product recalls and market withdrawal orders
• Reputational damage from public enforcement notices

Common enforcement triggers include:

• Missing or incorrect labels
• Failure to provide Safety Data Sheets
• Incorrect classification leading to inadequate hazard warnings
• Missing poison centre notifications
• Supply of chemicals without GB REACH registration where required

Getting help with compliance

HSE provides guidance and resources to help you comply. If you are unsure about your obligations, seek advice before placing products on the market. Industry trade associations can also provide sector-specific guidance.