News Brief
Recently, the UK Health and Safety Executive (HSE) submitted an important Technical Barriers to Trade (TBT) notification (Number: G/TBT/N/GBR/113) to the World Trade Organization (WTO).
The notification indicates that the UK proposes to revise the GB Mandatory Classification and Labelling List (GB MCL List), recommending the introduction of new or revised mandatory classification and labelling requirements for 60 hazardous chemical substances.
This update will have direct compliance implications for enterprises exporting chemicals and related mixtures to the UK market. REACH24H reminds relevant enterprises to pay timely attention to regulatory developments.
Regulatory Background
Since the UK officially left the EU on January 1, 2021, Great Britain (including England, Scotland, and Wales) no longer directly applies the EU CLP Regulation. Instead, it implements the independent Regulation on Classification, Labelling and Packaging of Substances and Mixtures (GB CLP Regulation). To ensure the proper functioning of the domestic market and to safeguard human health and environmental safety, the UK established its own GB Mandatory Classification and Labelling List (GB MCL List).
Timeline
This proposal is the result of a routine review under the UK’s independent regulatory framework. According to the proposal, these new classification standards are expected to be officially adopted in the second quarter of 2026, with a transitional period provided for enterprises, and are scheduled for mandatory enforcement starting from the fourth quarter of 2028.
Key Revisions
According to the technical document published by the HSE, this adjustment involves 60 substances, covering various industrial chemicals, pesticide active substances, and specific metal compounds. The core changes focus primarily on the reclassification of Carcinogenicity, Reproductive toxicity, and Mutagenicity (CMR), as well as hazards to the aquatic environment.
The following is a summary of some key substances and their proposed classifications.
CMR Substances (Carcinogenic, Mutagenic, Reprotoxic)
Trimethyl phosphate (CAS: 512-56-1): Proposed to be classified as Carcinogenicity 1B (Carc. 1B), Germ cell mutagenicity 1B (Muta. 1B), and Reproductive toxicity 1B (Repr. 1B).
Barium chromate (CAS: 10294-40-3): Proposed to be classified as Carcinogenicity 1B (Carc. 1B).
Boron compound series: Including sodium bromide, potassium bromide, magnesium metaborate, and various other boron/bromine compounds, which are generally proposed to be classified as Reproductive toxicity 1B (Repr. 1B), accompanied by specific concentration limits.
2,3-epoxypropyl isopropyl ether (CAS: 4016-14-2): Proposed to be classified as Reproductive toxicity 1B (H360F).
Environmental Hazard Substances
Copper compound series: A large number of copper compounds (such as cuprous oxide, copper hydroxide, copper carbonate, etc.) are included in the list, mainly involving acute toxicity and serious hazards to the aquatic environment (Aquatic Acute 1 / Aquatic Chronic 1), with M-factors established for some substances (e.g., M=10 or M=100).
Other Substances of Concern
Industrial and agricultural chemicals including Isophorone diisocyanate (IPDI, CAS: 4098-71-9) and Folpet (CAS: 133-07-3) are also included in the adjustment, involving classifications for skin sensitization, respiratory sensitization, and specific target organ toxicity.
Compliance Advice for Enterprises
In response to this GB CLP Regulation update, REACH24H suggests that relevant enterprises take the following measures:
Check Product Inventory: Compare product formulas to confirm whether they contain any of the 60 substances in the notification. Enterprises dealing with copper-based fungicides, boron-based flame retardants, and phosphate additives should pay particular attention.
Participate in Public Consultation: The deadline for public comments on this notification is March 27, 2026. If an enterprise believes that the proposed classification lacks scientific basis or would create unreasonable barriers to trade, it should submit feedback to the UK HSE through stakeholders or industry associations as soon as possible.
Update Technical Documentation in Advance: For products confirmed to be affected, it is recommended to start updating SDSs and labels for the Great Britain market as early as possible after the regulation is officially adopted, to avoid logistical backlogs or compliance risks as the mandatory effective date approaches.
Conclusion
The independent operation of the UK GB CLP Regulation means that enterprises can no longer rely solely on EU ECHA classification data but must independently monitor the regulatory dynamics of the UK HSE.
The classification adjustment of these 60 substances is one of the key compliance tasks for 2026. REACH24H reminds industry colleagues to closely follow the subsequent legislative process to ensure the completion of all compliance transitions before mandatory enforcement in the fourth quarter of 2028.
For more information and inquiries, please feel free to contact us at customer@reach24h.com.
