UK - GHS Status

The United Kingdom, consisting of Great Britain (England, Wales, and Scotland) and Northern Ireland was part of the European Union (EU) until Brexit. Therefore, when the sixth and seventh revised editions of the Globally Harmonized System for Classification of Chemicals (GHS 6 and 7) were implemented in the EU through EU Regulation 1272/2008, the UK was included. After Brexit, the UK adopted GHS through the GB Classification, Labelling and Packaging of Substances and Mixtures (GB CLP) Regulation, which is a replica of the EU CLP Regulation.

Brexit, short for "British exit", refers to the withdrawal of the United Kingdom from the EU. Negotiations between the UK and the EU led to the signing of the EU (Withdrawal) Act (2018), which came into force on 31 January 2020. This marked the end of the UK's membership of the EU and the beginning of a transition period, which lasted until 31 December 2020.

One aspect of Brexit was the need for the UK to establish its own regulatory framework for chemicals. Prior to Brexit, chemicals regulation in the UK was governed by the EU’s Registration, Evaluation, Authorization, and Restriction of Chemicals (EU REACH) Regulation. To address this, the UK introduced its own regulatory framework known as UK REACH which essentially mirrors the EU REACH Regulation. UK REACH regulates chemicals placed on the market in Great Britain (i.e. England, Scotland, and Wales), as EU REACH continues to apply in Northern Ireland under the terms of the Northern Ireland Protocol.

The UK REACH framework came into force on 1 January 2021, following the end of the transitional period. Since 2021, the UK has not independently adopted a revised version of the GHS and is therefore still implementing GHS 6 and 7.

Local Adaptation of GHS

The following GHS categories are not implemented in the UK:

• Flammable Liquids, Category 4
• Acute toxicity (oral, dermal and inhalation), Category 5
• Skin Corrosion/Irritation, Category 3
• Eye Irritation, Subcategory 2A and 2B
• Aspiration Hazard, Category 2
• Aquatic acute toxicity, Category 2 and 3

GHS Labelling Requirements

Substances and mixtures placed on the GB market must be classified and labelled in line with the GB CLP Regulation. The CLP Regulation defines the content of the label and the organisation of the various label elements. The label should be firmly attached to one or more of the packaging’s surfaces and must include the following elements:

• Name, address, and telephone number of the supplier(s)
• The nominal quantity of the substance or mixture in the packages where it is made available to the general public, unless the quantity is specified elsewhere on the package.
• Product identifiers (name and EC/CAS number)
• Hazards pictograms: Diamond shaped, size > 1 cm2
• Relevant signal words
• Hazard statements
• Precautionary statements (usually not more than six unless they are necessary to reflect the nature and the severity of the hazards)
• Supplemental information where relevant

Mandatory classification is a classification that is equivalent to the harmonised classifications that exist under EU CLP but within Great Britain it has been made legally binding. The GB Mandatory Classification and Labelling list (GB MCL) contains the legally binding mandatory classification and labelling of substances that must be used when classifying and labelling substances and mixtures that are to be placed on the market in Great Britain. When a substance has an MCL listing for some or all hazard classes, it must be applied by suppliers to the GB market. The GB MCL is hosted, managed, and operated by the Health and Safety Executive (HSE). As of November 2025, the MCL list contains 4430 substances. If a substance does not require mandatory classification (i.e. it is not in the GB MCL list), it must be self-classified for any hazard classes not covered by the mandatory classification.

Safety Data Sheets

The GHS provisions on Safety Data Sheets (SDSs) in Great Britain are based on the fifth revised edition of the GHS and are implemented through Article 31 and Annex II of the UK-REACH Regulations. The requirements for SDSs under UK-REACH are the same as under EU-REACH. The responsibility for SDSs is under the Department for Environment, Food, and Rural Affairs (DEFRA). SDS format requirements under EU REACH Annex II that were updated after 1 January 2021 (Brexit) do not apply in Great Britain.  An SDS in the UK must:

• Be in English
• Contain the 16 standard sections
• State the date it was last reviewed, or if it has not been reviewed, the date it was prepared.
• Contain an emergency contact number

The SDS must contain the information necessary to allow employers to do a risk assessment as required by the Control of Substances Hazardous to Health (COSHH) Regulations. The SDS itself is not an assessment. However, it describes the hazards helping employers assess the probability of those hazards arising in the workplace.

GHS in Transportation

In the UK, the national transport of dangerous goods is regulated under the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment (CDG) Regulations 2009 which came into force on 1 July 2009. The security provisions of the European Agreement Concerning the International Carriage of Dangerous Good by Road (ADR) and the Regulations Concerning the International Carriage of Dangerous Good by Rail (RID) apply in the UK through Regulation 5 of the CDG. Pictograms of chemical hazards used in ADR are based on the GHS transport labelling pictograms.