Manufacturing & Engineering UK-wide

Rubber and plastics manufacturer: compliance checklist

Use this checklist to confirm your rubber and plastics manufacturing business (SIC division 22) meets its obligations before a production run. Work through the universal workplace and chemicals items every manufacturer shares, then the sections for placing products on the market and for producing plastic packaging. If you answer no to any item, follow the linked guide before you proceed.

Guide summary

Go through this checklist before you start a production run. Answer yes or no to each item. If you answer no, follow the linked guide first. The checklist covers workplace safety, chemicals, product markings and plastic packaging. Different rules apply in Great Britain and Northern Ireland — check separately if you supply Northern Ireland.

  • Write risk assessments and set up safe systems of work
  • Control exposure to chemicals like resins and solvents (COSHH)
  • Guard and maintain machinery (PUWER) before each run
  • Assess manual handling and fire risks
  • Hold employers’ liability insurance of at least £5 million
  • Comply with equality law, GDPR and register with ICO if needed
  • Map your chemicals against UK REACH and check restrictions
  • Mark construction products with UKCA or CE before selling in GB
  • Type-approve and mark road tyres (new and retreaded)
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Related guides in Health & Safety

Use this checklist to confirm your rubber and plastics manufacturing business meets its obligations before a production run. Work through each item and answer yes or no. If you answer no, follow the linked guide before you proceed.

Workplace health and safety is enforced by the Health and Safety Executive in Great Britain and by HSENI in Northern Ireland. UK REACH and the product-conformity regimes are Great Britain regimes — UKCA is the GB mark where one is required and CE marking also continues to be accepted on the GB market. If you supply Northern Ireland, check the position separately, because NI follows EU rules under the Windsor Framework. Packaging producer responsibility and the Plastic Packaging Tax are UK-wide. Each section names the body that applies.

Section 1 — Every rubber and plastics manufacturer

These workplace, chemicals and registration duties apply to every manufacturer, whatever you make. Confirm each one before you start production.

  1. 1

    Have you written your risk assessments and put safe systems of work in place?

    Your general duty under the Health and Safety at Work etc. Act 1974 is to ensure, so far as is reasonably practicable, the health, safety and welfare of your people. Risk-assess moulding, extrusion, curing and finishing and put safe systems of work, training and supervision in place. If not, follow "Set up and run a safe rubber or plastics factory".

  2. 2

    Have you assessed and controlled exposure to your process chemistries?

    COSHH requires control of resins, curing agents, plasticisers, solvents, isocyanates and rubber fume, with local exhaust ventilation and health surveillance where required.

  3. 3

    Is your machinery safeguarded, maintained and inspected under PUWER?

    Moulding machines, extruders, calenders, mills and granulators must be guarded, maintained and safely isolated for cleaning under PUWER.

  4. 4

    Have you assessed manual handling and carried out your fire risk assessment?

    Reduce hazardous handling of materials, moulds and product. Assess fire risk from polymers, solvents and dust under the fire-safety regime for your nation.

  5. 5

    Do you hold employers' liability insurance and meet your equality and data duties?

    Hold at least £5 million of cover once you employ anyone. Do not discriminate under the Equality Act 2010 (or separate NI equality law enforced by the ECNI). Comply with the UK GDPR and Data Protection Act 2018, registering with the ICO unless exempt.

  6. 6

    Have you mapped your substances against UK REACH?

    Identify what you must register, check the Annex XVII restrictions on your plasticisers and additives, and pass SVHC information down the supply chain. UK REACH is a GB regime. Check the NI position separately under EU REACH if you supply there.

Section 2 — Placing products on the market

If you make products to sell, confirm the regime for each product. The construction-products, tyre and general-product-safety regimes are Great Britain regimes. Food-contact materials are enforced per nation. Check Northern Ireland separately if you supply there.

  1. 1

    Do your plastic builders' ware and construction products carry the right marking?

    Designated-standard products (PVC-U windows, pipes, cladding) need a declaration of performance and conformity marking (UKCA, or CE which is still accepted on the GB market) before the GB market. If not, follow "Place rubber and plastic products on the market".

  2. 2

    Are your tyres type-approved and marked?

    New and retreaded road tyres must meet UN/ECE type-approval standards (retreads to UNECE 108/109), carry the required marking and meet tyre-labelling rules.

  3. 3

    Do your food-contact materials meet the food-contact rules?

    Plastic tableware, containers and food packaging must comply with Regulation (EC) 1935/2004 and Regulation (EU) 10/2011, follow good manufacturing practice and have a declaration of compliance, enforced by the FSA / Food Standards Scotland with local authorities.

  4. 4

    Do other products meet the general product safety duty?

    Goods outside a specific regime must still be safe under the General Product Safety Regulations 2005, enforced by OPSS and Trading Standards.

Section 3 — Plastic packaging producers (SIC 22.22)

Only complete this section if you manufacture plastic packaging. These reporting and tax duties are UK-wide.

  1. 1

    Are you registered for packaging producer responsibility (EPR) and reporting your data?

    If you cross the EPR thresholds (broadly £1m / 25 tonnes for small producers, £2m / 50 tonnes for large), you must report packaging data through the Report packaging data service and, for large producers, pay disposal fees. Enforced by the Environment Agency, SEPA, NRW or NIEA. If not, follow "Meet packaging producer responsibility and Plastic Packaging Tax".

  2. 2

    Are you registered for the Plastic Packaging Tax if you cross the threshold?

    If you manufacture 10 or more tonnes of finished plastic packaging in a 12-month period, register with HMRC, file quarterly returns and pay the tax on packaging with under 30% recycled plastic, keeping records of recycled content.

If you answered no to anything

Work through the guide linked in that item before your production run. The three task guides — the safe-factory spine, placing products on the market, and packaging producer responsibility and Plastic Packaging Tax — set out what to do. Start from the router if you are not sure which apply to you.

Official sources

Authoritative health and safety, product-conformity and packaging guidance.