United Kingdom SDS Authoring
National Regulations Governing SDSs
Following the UK’s departure from the EU and the end of the transition period on December 31, 2020, the UK implemented its own chemical safety legislation. If you manage Safety Data Sheets (SDS), it’s essential to understand which regulations apply and where.
In England, Scotland, and Wales, SDS authoring is now governed by:
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UK REACH Regulation – established by The REACH etc. (Amendment etc.) (EU Exit) Regulations 2020, adapting the EU REACH Regulation (EC) No 1907/2006.
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GB CLP Regulation – based on EU CLP Regulation (EC) No 1272/2008, modified for domestic use.
These laws are enforced by the Health and Safety Executive (HSE) and apply to substances and mixtures placed on the GB market.
Under the Northern Ireland Protocol, EU REACH and EU CLP regulations still apply. This maintains regulatory alignment with the EU single market and is enforced by HSENI.
To summarize:
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UK SDS = Follows UK REACH + GB CLP → for Great Britain only
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EU SDS = Follows EU REACH + EU CLP → required for Northern Ireland
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.
GHS Implementation Status
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.