GB CLP Regulation: New Chemical Classifications and Deadlines

On February 15, 2025, the UK Health and Safety Executive (HSE) published the 6th edition of the GB Mandatory Classification and Labelling (GB MCL) List. This update introduces new classifications for 46 substances and outlines key compliance deadlines, including a final deadline of August 15, 2026.

The GB CLP Regulation, effective since January 1, 2021, governs the classification, labelling, and packaging of chemicals in Great Britain. Although it largely aligns with the EU CLP Regulation, it has unique requirements for notification and uses GB MCL instead of EU harmonized classifications.

Updates in the 6th Edition of the GB MCL List

1. New Substance Classifications

Several new substances have been classified, including:

o Nonylphenol ethoxylates (used in detergents and personal care products)
o Hydrogen sulfide (found in the oil & gas industry)
o Diuron (herbicide used in agriculture)
o 1-Phenylethylidene hydrazone (used in specialty manufacturing)

2. Corrections and Clarifications

The HSE has made corrections to previous entries, ensuring more precise classifications and labels.

3. Divergence from EU CLP Regulations

o GB MCL replaces EU harmonized classifications.
o UK-based companies must notify new substances to HSE, not ECHA.
o The GB CLP Regulation does not adopt post-Brexit updates from the EU CLP.

Updates in the 4th Edition of the GB MCL List

1. Addition of 25 Substances

o Potassium Chlorate (CAS 3811-04-9): Classified as an oxidizing solid (Category 1) and acute oral toxicity (Category 4).
o Sodium Chlorate (CAS 7775-09-9): Classified as an oxidizing solid (Category 1) and acute oral toxicity (Category 3).
o Cinnamaldehyde (CAS 104-55-2): Classified for skin sensitization (Category 1) and acute dermal toxicity (Category 5).
o Allyl Methacrylate (CAS 96-05-9): Classified for acute oral toxicity (Category 3) and skin corrosion/irritation (Category 2).

2. Implementation Dates

o Entry into Force: March 2, 2024
o Compliance Date: September 2, 2025

3. Alignment with EU Regulations

The updates reflect the 14th and 15th Adaptations to Technical Progress (ATPs) of the EU CLP Regulation to ensure consistency in chemical safety standards between the UK and the EU.

Impact on Industries

The updated GB MCL List will affect various industries, including:

• Chemical & Manufacturing: Product formulations and Safety Data Sheets (SDS) will need to be updated to reflect new hazard classifications.
• Pharmaceutical & Biotechnology: Toxicological classification changes may require adjustments in chemical handling.
• Agriculture & Pesticides: Herbicides like diuron now have revised hazard classifications.
• Oil, Gas & Mining: New classifications for hydrogen sulfide will impact worker safety.
• Cosmetics & Consumer Goods: Reformulations may be necessary for substances like nonylphenol ethoxylates.

Challenges of GB CLP Compliance

1. Regulatory Complexity: Businesses must navigate both GB and EU regulations, leading to separate compliance strategies.
2. Supply Chain Adjustments: Different chemical classifications across regions may complicate sourcing materials.
3. Labelling & SDS Updates: Product labels and employee training need revisions to meet new requirements.
4. Increased Costs: Reformulating products, conducting testing, and updating documentation could raise operational expenses.

Strategies to Address the Challenges

1. Regulatory Monitoring: Regularly track updates from the HSE and ECHA to stay ahead of classification changes.
2. Supply Chain Due Diligence: Audit suppliers to ensure alignment with GB MCL requirements.
3. SDS & Labelling Updates: Revise Safety Data Sheets, labels, and training materials by the August 2026 compliance deadline.
4. Stakeholder Engagement: Participate in HSE consultations to provide feedback on regulatory changes.
5. Investment in Safer Alternatives: Consider replacing newly classified hazardous substances with safer chemicals.

For further details, visit the HSE’s publication here.