Update to GB CLP Mandatory Classifications expected Q4 2023

Attention to all GB based manufacturers, importers and downstream users  whose substances are affected by GB CLP

 Background information:

Due to the United Kingdom’s withdrawal from the European Union, Great Britain (GB) – which includes England, Scotland, and Wales- no longer implements the Harmonised classifications and labelling requirements of Annex VI of “Regulation (EC) No 1272/2008 of the European Parliament and of the Council of 16 December 2008 on classification, labelling and packaging of substances and mixtures, amending and repealing Directives 67/548/EEC and 1999/45/EC, and amending Regulation (EC) No 1907/2006” (EU CLP).  Instead, EU CLP as it stood on 31st December 2020 was retained in GB law with modifications to address deficiencies arising from the UK’s withdrawal from the EU, the Withdrawal Agreement and the Northern Ireland Protocol.  The changes are set out in The Chemicals (Health and Safety) and Genetically Modified Organisms (Contained Use) (Amendment etc.) (EU Exit) Regulations 2019 No. 720[1, specifically Schedule 2, paragraphs 12-57, and further amended by The Chemicals (Health and Safety) and Genetically Modified Organisms (Contained Use) (Amendment etc.) (EU Exit) Regulations 2020 and is referred to as “GB CLP”. 

Status today:

Under GB CLP, Part 3 of Annex VI of EU regulation No. 1272/2008, the harmonised classifications and labelling of EU CLP, was deleted and replaced with in the GB mandatory classification and labelling list GB MCL). The GB MCL included the Classifications and labelling as per the EU table 3 of Annex VI up to and including the 14th and 15th ATP to EU CLP.  Any subsequent changes to EU CLP Annex VI are considered by the UK Authorities, but are not automatically included in GB CLP, including those which were updated in EU CLP by the 16th (Commission Delegated Regulation (EU) 2020/217 and corrigendum) and 17th ATPs (Commission Delegated Regulation (EU) 2020/1182).  The UK Authorities may also choose to include mandatory classifications for substances which do not have EU Harmonised classification and labelling.

REACHLaw UK is following closely on the matter:

It has come to our attention that the intended first update to the GB MCL has been communicated to the World Trade Organisation (WTO)  with a target date for adoption in Quarter 4 2023, and a transition period in which the new / amended classifications can be used on a voluntary basis until quarter 4 2024, at which point they new / updated classification will become mandatory.  This update affects the classifications of 98 substances.  Government Officials can submit comments to the WTO Committee on Technical Barriers to Trade until 4 June 2023

Contact us at sales@reachlaw.fi for support. REACHLaw UK would be happy to support you with GB CLP and related updates.


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