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What companies should expect post- transition period Prepare for after the transition period- CLP

Updated: Dec 10, 2020

The transition period ends on 31 December 2020. From 1 January 2021, the European Union (EU) CLP Regulation will be replaced in Great Britain by retained EU law – the GB CLP Regulation.

Businesses based in Great Britain (England, Scotland and Wales) that place chemicals (substances and mixtures) on the GB market will have to comply with the GB CLP Regulation

Things we know now!

Northern Ireland Protocol- At the end of the transition period, the Northern Ireland Protocol will take effect. The Protocol is a practical solution to avoid a hard border with Ireland whilst ensuring the UK, including Northern Ireland, leaves the EU, enabling the entire UK to benefit from future Free Trade Agreements. NI will still have access to the EU market after the transition period. Companies established in NI comply with EU CLP. Similarly, a chemical substance or a mixture produced in NI and shipped to the EU will not be classified as an ‘imported product’. However, products shipped from GB to NI will have to follow the relevant import Regulation.

What will be the same from January 2021?

The main duties on GB-based businesses i.e. manufacturers, importers, downstream users and distributors/suppliers to classify, label and package the chemicals (substances and mixtures) they place on the market under the GB CLP Regulation will stay the same.

Classification, Labelling and Packaging- GB-based manufacturers, importers and downstream users will still have to classify, label substances and mixtures and identify any hazardous properties, before they place them on the GB market. Substances and mixtures placed on the GB market must still be safely and securely packaged. Requirements for child resistant closures and tactile warning devices will remain in place.

Poison Centre- GB-based business placing hazardous products on the GB market, on basis of their health or physical effects according to the criteria laid down in EU-GHS are required to notify HSE.

UN GHS - The GB CLP Regulation will continue to adopt the United Nations Globally Harmonized System of classification and labelling of chemicals (UN GHS) in a similar way to the EU CLP Regulation.

There are no changes to requirements for when GB CLP Regulation labelling appears alongside those for transport.

What will change for GB-based businesses from January 2021?

GB CLP Agency- HSE is the competent authority in the GB

GB mandatory classification and labelling (GB MCL) - GB-based businesses are required to classify and label their substances, where required, in accordance with GB MCL and with the entries in the GB MCL list hosted and managed by HSE.

GB Notification- GB-based businesses will be required to notify HSE of the classification and labelling of the substances they place on the GB market, whether on their own or in mixtures, where they meet the criteria for notification.

Downstream users and distributors supplied from the EU & EEA

The GB-based downstream user or distributor will become an importer after the end of the transition period if these supply arrangements continue. There will be new requirements on GB-based downstream users and distributors who are currently supplied by businesses in the EU/EEA. Read C4C bite size guidance on PIC and REACh.

Exporting to the EU/EEA- Responsibility for the classification, labelling and packaging of chemicals exported to the EU/EEA from Great Britain will rest with the EU/EEA-based importer or the arrangements between the GB-based business and EU/EEA business.

Poison Centre & UFI- GB-based business are required to appoint an EU representative, create UFI, where relevant and submit a notification in each Member State in which hazardous chemical products are marketed.

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