2026 GB CLP Update Removes C&L Notification: What Chemical Suppliers Need to Know

Key GB CLP Changes at a Glance

The change affects manufacturers and importers based in Great Britain, as well as suppliers based in Northern Ireland that directly supply substances to Great Britain. However, it removes only the separate notification requirement. It does not remove companies' responsibilities for hazard classification, labelling, packaging or the provision of Safety Data Sheets where required.

The Regulations also introduce a revised legal framework for adopting new or revised GB Mandatory Classification and Labelling requirements, commonly known as GB MCLs. HSE is currently implementing the new system, while the existing GB MCL process continues under transitional arrangements.

What Is the Scope of GB CLP?

GB CLP governs the classification, labelling and packaging of substances and mixtures placed on the market in England, Scotland and Wales.

Northern Ireland remains subject to the EU CLP framework for substances placed on the Northern Ireland market. HSE therefore makes an important distinction:

• A GB-based manufacturer or importer no longer needs to notify HSE of substance classification and labelling information.

• A Northern Ireland-based supplier directly supplying the Great Britain market also no longer needs to make a GB notification.

• A company placing substances on the Northern Ireland market must continue to assess its notification obligations under EU CLP, including notification to the ECHA Classification and Labelling Inventory where applicable.

Companies supplying both markets should maintain clear procedures distinguishing Great Britain from Northern Ireland and the EU.

1. GB Classification and Labelling Notification Is No Longer Required

SI 2026/484 revokes Chapter 2 of Title V of GB CLP, which previously established classification and labelling notification requirements and the related GB notification database.

As a result, affected companies no longer need to submit new or updated classification and labelling information to HSE for substances placed on the Great Britain market.

The Regulations also remove consequential references to the GB notification database from GB CLP and certain related references from UK REACH.

Importantly, the change concerns the notification of classification information, not the obligation to classify chemicals. Suppliers must still determine the appropriate hazard classification and communicate that information through compliant labels and, where required under UK REACH, Safety Data Sheets.

2. A Revised Process for Adopting GB MCLs

The Regulations replace the former Articles 37 and 37A with a single new Article 37. It establishes separate procedures for fast-track proposals and other proposals.

Fast-track proposals

A proposal may qualify for the fast-track route if it comes from a territory—including the European Union—or a state authority that HSE considers to have:

• adopted the UN GHS in a manner similar to the United Kingdom; and

• established a transparent classification proposal system based on public consultation.

For a fast-track proposal, HSE must publish a technical report according to its work plan. Where HSE considers a new or revised GB MCL appropriate, it must submit a recommendation to the Secretary of State within 12 months after publishing the report.

Other proposals

Proposals that do not meet the fast-track criteria follow the procedure for other proposals. These may originate from HSE, a competent authority or, in specified circumstances, a manufacturer, importer or downstream user.

This route includes an opportunity for interested parties to comment, followed by an HSE technical report and opinion before any recommendation is submitted to the Secretary of State.

The new legal framework may support more efficient consideration of classification conclusions developed under comparable GHS-based systems. It does not, however, mean that classifications adopted by the EU or another jurisdiction will automatically become legally binding in Great Britain.

HSE states that it is still implementing the new GB MCL system and that the current system will continue during the transition. Companies should therefore monitor further HSE guidance rather than assuming that the new process is already fully operational.

3. Transitional Arrangements for Existing Proposals

The procedural changes do not apply retrospectively to certain work already in progress before 21 May 2026. The previous procedures continue to apply to:

• an ECHA Committee for Risk Assessment opinion published before the commencement date; and

• a mandatory classification proposal received by or produced by HSE before the commencement date.

Companies involved in an existing GB MCL proposal should confirm which procedure applies before planning submissions, comments or regulatory engagement.

What Has Not Changed?

SI 2026/484 does not itself introduce new GHS hazard classes or change the core technical criteria used to classify chemical hazards.

Companies remain responsible for:

• classifying substances and mixtures placed on the Great Britain market;

• applying legally binding classifications in the GB MCL List;

• preparing compliant GB labels, including applicable pictograms, signal words, hazard statements and precautionary statements;

• meeting GB CLP packaging requirements; and

• providing compliant Safety Data Sheets under UK REACH where the relevant conditions are met.

Companies generally should not revise labels or SDSs solely because the C&L notification requirement has been removed. A review may nevertheless be needed when:

• HSE adopts a new or revised GB MCL;

• the composition or concentration of a product changes;

• new toxicological or ecotoxicological information becomes available; or

• the supplier's classification assessment changes.

What Should Chemical Suppliers Do Next?

Companies placing chemicals on the Great Britain market should consider the following actions:

1. Update internal procedures. Remove the former HSE C&L notification step from applicable GB compliance workflows.

2. Confirm the destination market. Distinguish supplies to Great Britain from supplies to Northern Ireland or the EU, where EU CLP notification requirements may still apply.

3. Retain classification documentation. Maintain the data, scientific rationale and decision records supporting self-classification, even though the separate HSE notification is no longer required.

4. Review GB labels and SDSs. Confirm that labels comply with GB CLP and that Safety Data Sheets meet applicable UK REACH requirements.

5. Monitor GB MCL developments. Track the HSE work plan, GB MCL List and further guidance on implementation of the new process.

6. Manage UK–EU divergence. Products supplied to both markets should be covered by separate regulatory change-control processes rather than relying on a single EU/GB compliance assumption.

For a wider comparison of national hazard communication systems, see REACH24H's Globally Harmonised System by Country and Region.

How REACH24H Can Help

REACH24H supports companies managing chemical compliance requirements across Great Britain, the EU and other GHS jurisdictions. Relevant services include:

• GB CLP applicability and supplier-role assessment;

• substance and mixture classification review;

• GB and EU classification comparison;

• SDS preparation, review and updating;

• chemical label review and verification;

• GB MCL and EU CLP regulatory monitoring; and

• UK REACH compliance support.

Recommended Reading

• Global GHS, SDS/MSDS and Label Compliance

• Globally Harmonised System by Country and Region

• UK Seventh Edition GB Mandatory Classification and Labelling List Released

• UK Proposes Revision of GB MCL List for 60 Substances

Official References

• HSE: Changes to the GB CLP Regulation

• The Chemicals (Health and Safety) (Amendment, Consequential and Transitional Provision) Regulations 2026

• HSE: GB Mandatory Classification and Labelling List