Differences in Labeling Requirements Between the CLP in the EU and the UK

The UK defined its own binding classifications for 98 substances for the first time on October 20 as part of its post-Brexit chemicals legislation. The agency responsible for the legislation, the Health and Safety Executive (HSE), followed the recommendations of its Regional Advisory Council. The Council classified 15 of the 98 substances differently than the corresponding EU body, the Risk Assessment Committee (RAC).

Analysis reveals that the EU assessed substances more strictly than the UK in twelve cases. The best example is the assessment of the biocide azamethiphos. The EU authority classifies the substance as a category 2 carcinogen, but the UK authority did not recognize a clear dose-response relationship or a statistical significance that would justify a cancer classification. However, the extent of the deviations is smaller for the other substances.

Nevertheless, the differences in labeling requirements remain a challenge for companies that operate in both markets. That’s especially true if the trend continues and the EU generally sets stricter labeling requirements than the UK does. The companies concerned will clearly have more work in the future because they must then label their products differently in the two markets.

If you are active on the British market please do not hesitate to contact us at sales@kft.de.