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Navigating GHS in Britain post-Brexit: Expect to see further divergence between the EU and GB

from CIRS by


When Brexit was enacted and the UK left the EU on January 31, 2020, it took certain regulations that were in force and wrote them directly into GB regulations.

From that point forward, Great Britain (England, Scotland, and Wales) began adhering to the GB Classification, Labelling and Packaging of Chemicals Regulation (GB CLP).

However, the Northern Ireland agreement means that European Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures (EU CLP) is still required in Northern Ireland.

It should be noted that any updates to EU CLP that took place after January 31, 2020, do not apply to GB CLP.

Since both CLP regulations have the same starting basis they do maintain a lot of similarities including:

  • Safety data sheet (SDS) – both regulations include a standard 16-section SDS, although some content may differ between GB and EU (see more below);
  • Pictograms – both regulations use all nine GHS pictograms; and
  • Mandatory classifications.

Under EU CLP Annex VI there is a list of mandatory classifications referred to as the harmonised classification and labelling of hazardous substances. The UK has a similar list called GB mandatory classification and labelling list (GB MCL list). 

These mandatory classification lists are constantly being updated and must be adhered to in the relevant jurisdictions. Both lists are available to download as excel documents from the European Chemical Agency (ECHA) and Health and Safety Executive (HSE) websites respectively (see links below).


The EU Updated Regulation (EU) 2020/878, introduced various changes including some to the SDS format, which now aligns with the eighth revised edition of GHS. While the revisions applied from January 1, 2021, a transition period permitted the old format to be used until December 31, 2022.

So starting this year, we can expect to see further divergence between the two systems with GB CLP provisions on SDSs adhering to the seventh revised edition of GHS.

The EU requires an EU legal entity to be listed on the SDS and label. So if you are a British company producing a product in GB that you also sell in the EU, you cannot be the EU supplier, you will need a separate EU legal entity for the EU SDS and label, and vice versa.

UFI codes

When the GB CLP regulation was authored, Great Britain copied most of the regulation directly from the existing EU CLP. This meant that Annex VIII was unintentionally included. This lays out that importers and downstream users must follow a harmonized format in notifying appointed bodies about their hazardous mixtures. This is referred to as poison centre notification (PCN). A unique 16-digit alphanumeric code (VDU1-414F-1003-XXXX) known as a Unique Formula Identifier (UFI) code is used to link the submitted information to the hazardous mixture. It can be generated by using a UFI Generator on ECHA website.

Prior to Brexit, the UK authorities told industry that this would be a voluntary requirement. However, when Annex VIII was copied into law it legally became a mandatory requirement.

Due to significant backlash from industry, authorities have maintained that they still only consider it a voluntary requirement. However, this could change in the future. The authorities could work on having the requirement legally removed from the regulation, which would require government approval, or they could decide to make it mandatory in the future. So it is important to keep an eye on this topic.

You can choose to put a UFI code on your product in GB but it must be for a GB poison centre, not an EU poison centre. Please note, choosing to include a GB UFI code will not lead to a non-classification.

Expect further divergence

After three years, the two systems are already different and they are likely to continue to grow further from each other due to the current and future updates.

We already know that there is also a plan for the entire EU CLP to be updated before 2024. This would lead to further divergence between the two regulations because one substance could be classified differently under each CLP regulation.

CIRS is to host a free webinar about a general overview of the requirements for European Regulation on classification, labelling and packaging of substances and mixtures (EU CLP). Including requirements for safety data sheets (SDSs) and labels on February 2, 2023. To know more information about this webinar, please click here.

We will continue to provide you with updates. And if you need any assistance with GB or EU CLP, please reach out to us via

Further information

GB MCL list



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+353 1 477 3710 (EU)
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Contact Us
+353 1 477 3710 (EU)
+44 20 3239 9430 (UK)
+1 703 520 1420 (USA)
+86 571 8720 6574 (CN)
+82 2 6347 8816 (KR)