When you make chemical substances or products, you cannot simply start supplying them. You must first register or authorise what you make where the law requires it, classify the hazards, and label and package the product correctly. This guide is for makers of chemicals and chemical products (SIC division 20) placing substances and products on the market in Great Britain.
Several separate regimes can apply to the same product at once. A disinfectant, for example, is a substance or mixture under REACH and CLP and a biocidal product needing authorisation before sale. Work out which apply to your product, then satisfy each one before you place it on the market.
Every regime in this guide is a placing-on-the-GB-market matter: it applies when you make a product available on the market in England, Scotland or Wales. Northern Ireland follows the EU rules under the Windsor Framework, so check the NI position separately if you supply there.
Register your substances under UK REACH
Start here, because registration is the gateway for most substances. If you manufacture a substance at one tonne a year or more, you must register it with the HSE-run UK REACH service and supply safety data sheets down the chain. Registration covers the substance itself, before any consideration of how it is labelled or sold. Authorisation and restriction requirements may also apply to substances of concern.
Classify, label and package under GB CLP
Every substance and mixture you place on the GB market must be classified for its hazards, then labelled with the correct pictograms, signal words and hazard and precautionary statements, and packaged safely. This is what the customer sees on the container. GB CLP works alongside REACH: REACH covers registering the substance, CLP covers communicating its hazards.
Authorise the product, if it is a biocide, pesticide or cosmetic
Some products need authorisation or notification on top of REACH and CLP. This applies only to specific product types — if your product is not one of these, skip this section. Biocidal products need active-substance approval and product authorisation. Plant protection products need the product authorised and its active substances approved. Cosmetic products need a UK responsible person, a safety assessment and notification before sale. Identify which one fits your product and follow its route.
Steps to place your product on the GB market
Whichever regimes apply to what you make, the placing-on-market sequence is the same. Work through it in order; the early steps decide how much work the later ones involve, and the product authorisation routes take the longest, so start them early.
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1. Classify your product
Identify exactly what you make — a substance, a mixture, a biocide, a plant protection product or a cosmetic. This decides which registration, classification and authorisation regimes apply.
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2. Register substances under UK REACH
Register each substance you manufacture at one tonne a year or more with the UK REACH service, and prepare the safety data sheets you must supply down the chain.
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3. Classify the hazards and prepare CLP labelling
Classify each substance and mixture for its hazards under GB CLP, then draw up the label — pictograms, signal word, and hazard and precautionary statements — and confirm the packaging is safe and compliant.
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4. Obtain any product authorisation
If your product is a biocide, plant protection product or cosmetic, complete the authorisation or notification route for it before you place it on the market. Allow time, as these routes can be lengthy.
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5. Compile and keep your documentation
Keep your registration records, safety data sheets, classification records and any product information file or authorisation, so you can produce them for HSE, OPSS or trading standards on request.
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6. Label, package and place on the market
Apply the CLP label and any product-specific markings, package the product safely, and only then place it on the GB market.
What to do next
Placing product on the market is only part of your obligations. If you operate a major-hazard site, run an industrial-scale installation, or make or store explosives, read the companion guide on operating a safe chemical manufacturing site. Run the chemical manufacturer compliance checklist before any production run to confirm each regime is satisfied. If you import rather than manufacture, check the supplier has met each requirement and that the product is correctly registered, classified and labelled before you place it on the GB market. Before you supply in Northern Ireland, check the position there separately, as NI follows the EU rules under the Windsor Framework.
Official sources
Statutory sources and regulators for placing chemicals on the GB market