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United Kingdom is a member of the European Union and as such is bound by EU regulations. For pure substances, UK Safety Data Sheets (SDSs) must be compliant with the EU’s GHS based CLP-regulation No. 1272/2008 – SDSs authored to be compliant with Directive 67/548/EEC have expired. For mixtures, SDSs can be compliant with either 1272/2008 or with the previous Directive 1999/45/EC.
The UK is split into four regions (England, Northern Ireland, Scotland, and Wales) each with their own procedures for environmental protection and enacting EU chemical legislation. For information on policy from Northern Ireland and Scotland please refer to their Environmental Guidance for Your Business Page. For England information, support and compliance please refer here. For Wales please refer here. For the UK in general please refer to the Environment Agency page.
The EU has fully adopted GHS under their CLP Regulation (Regulation on classification, labeling and packaging of substances and mixtures). The deadline for having new SDSs has passed for pure substances – it was November 30, 2010. The deadline for mixtures was May 31, 2015. Not all the building blocks in the United Nations’ Purple Book were adopted by the EU CLP regulation. Furthermore, the EU has adopted the EU No 453/2010 format for SDSs, which goes well beyond what was recommended in the Purple Book.
It is relatively straight forward to have a single MSDS for use among the countries of the European Union and European Free Trade Association, so long as it is in the necessary languages. Countries other than the United Kingdom in the EU and EFTA where English is an official language include Malta and Ireland. Having a single document for use in the United States and the European Union should be avoided due to significant differences between the two systems.