In 2021, the UK left the European Union (Brexit) and implemented its own regulatory framework for chemical products. Since then, chemical products placed on the market in Great Britain (England, Scotland and Wales) must comply with UK REACH and GB CLP instead of their EU counterparts.

In the UK, the format of the Safety Data Sheet (SDS) is regulated by UK REACH, Annex II, with GB CLP providing the classification framework; both regulations broadly align with the seventh revision of the GHS (GHS Rev. 7). Articles 31 and 32 of UK REACH provide further information on how SDS are to be managed and the requirement for them within the chemical product supply chain.

Due to the complexities of Brexit and political sensitivities, products placed on the market in Northern Ireland are governed by the Northern Ireland Protocol, amended by the Windsor Framework. This states that products placed on the market in Northern Ireland should comply with European legislation to prevent the need for a hard border with the Republic of Ireland.

For companies exporting chemicals to Great Britain, understanding local legislation is essential to avoid regulatory non-compliance and ensure that the documentation supplied meets current requirements.

This guide covers:

• The regulations governing Safety Data Sheets in Great Britain.
• The difference between UK REACH and the EU REACH Regulation.
• The role of GB CLP in classification and labelling.
• The specific requirements SDS must meet.
• The differences between an EU SDS and an SDS for Great Britain.
• Good practices for keeping SDS up to date and compliant.

Summary

Key takeaway

Since Brexit, Great Britain has its own regulatory framework for chemicals. Although it remains aligned with EU legislation, companies must ensure their Safety Data Sheets meet UK REACH and GB CLP requirements before placing a product on the GB market.

Which regulations govern Safety Data Sheets in the United Kingdom?

After the UK left the European Union, it initially undertook a “Life and Shift” mechanism to implement the existing EU law into UK legislation. Since then, UK authorities have amended elements of this legislation to not automatically implement new areas of EU law, diversifying the two regions in certain areas. Therefore, the UK should be considered legislatively separate from the EU.

Safety Data Sheets marketed in Great Britain are governed mainly by two regulations:

• UK REACH Regulation, which provides the requirements and format of the SDS alongside the major objectives of the REACH regulation, detailing the Registration, evaluation, authorisation and restriction of chemicals.
• GB CLP Regulation, which sets out the rules on the classification, labelling and packaging of substances and mixtures. These classification requirements heavily impact the SDS.

Although both regulations retain a structure very similar to the EU REACH and CLP Regulations, regulatory differences have already emerged, making it necessary to review documentation before marketing chemicals in Great Britain.

UK REACH

The UK REACH Regulation is the main UK regulatory framework for the management of chemical substances.

Its aim is to ensure a high level of protection for human health and the environment while facilitating the operation of the UK chemicals market. It ensures a high level of protection for human health and the environment while facilitating operations of the UK chemicals market.

It also governs:

• substance registration
• risk assessment
• authorisation procedures
• restrictions applicable to certain substances
• obligations relating to Safety Data Sheets

GB CLP

The classification and labelling of hazardous substances and mixtures are governed by the GB CLP Regulation.

This regulation sets out:

• hazard classification criteria
• mandatory labelling elements
• packaging requirements
• obligations relating to the communication of chemical hazards

GB CLP remains closely aligned with the EU CLP Regulation, but future regulatory amendments may differ between the two jurisdictions.

Companies should therefore periodically check that the classification of their products remains valid in both the European Union and Great Britain.

Regulation of Safety Data Sheets

Requirements relating to Safety Data Sheets can be found in Articles 31/32 and Annex II of the UK REACH regulation.

The SDS must follow a standardised 16-section format as dictated by GHS and include all the information needed to ensure safe use of the product. Administrative details such as supplier information and emergency phone numbers must be GB-specific, and data including workplace exposure limits and mandatory classifications should come primarily from UK sources.

Competent authorities

Health and Safety Executive (HSE)

While governed by two different competent authorities, the Health and Safety Executive (HSE) does much of the day-to-day administration of UK chemical legislation.

Its main tasks include:

• Driving UK policy on GB CLP
• Providing guidance on the implementation of REACH/CLP and other chemical legislations
• Managing the administration of UK REACH and other regulations, including the Biocidal Product Regulations (BPR)
• Overseeing compliance with chemical legislation

However, UK REACH (alongside other chemical legislation) is under the remit of the Department of Environment, Food and Rural Affairs (DEFRA). Although DEFRA covers a wide range of areas, it focuses on UK policy for REACH and BPR, among other chemical regulations.

How are UK REACH, REACH and GB CLP related?

One of the most common questions from manufacturers and importers is whether an SDS compliant with the REACH Regulation can be used directly in Great Britain.

The answer is: it depends on the product and the regulatory context at the time.

At present, UK REACH and the EU REACH Regulation remain reasonably aligned because both derive from the same EU legislation. The level of alignment is becoming highly dependent on the current political party in power. This has resulted in dramatic swings as the government has changed.

Over time, this means differences have emerged in relation to:

• substance restrictions
• authorisations
• hazard classifications
• regulatory references
• administrative requirements
• competent bodies

Companies should therefore not assume that an SDS valid in the European Union will automatically be valid in Great Britain.

Before marketing a chemical product in GB, it is advised to check that the documentation contains the correct regulatory references and reflects the requirements of UK REACH and GB CLP.

When is a Safety Data Sheet mandatory in the United Kingdom?

Obligations relating to SDS in Great Britain arise mainly under the UK REACH Regulation.

SDS’s must generally be supplied when a hazardous substance or mixture is marketed for professional or industrial use and meets the criteria set out in UK legislation.

The aim is to ensure for downstream users, distributors and workers to have enough information to handle, store and use chemical products safely.

Which products require an SDS?

Generally, a Safety Data Sheet must be provided for:

• substances classified as hazardous under the GB CLP Regulation
• mixtures classified as hazardous
• certain persistent, bioaccumulative and toxic (PBT) or very persistent and very bioaccumulative (vPvB) substances, where applicable
• other products for which UK REACH requires an SDS to be supplied

In addition, an SDS may also be required for a mixture that is not classified as hazardous if it contains certain components above specific regulatory thresholds and the recipient requests one for professional use.

The obligation must be assessed on a case-by-case basis in accordance with UK REACH requirements.

SDS may also be requested voluntarily by downstream users for products that do not meet the requirements listed above. This is particularly common with large retailers.

Who must provide the SDS?

Responsibility lies with the supplier of the chemical product, who may be:

• the manufacturer
• the importer
• the only representative, where applicable
• the distributor placing the product on the UK market

The supplier must ensure that the documentation:

• accompanies the initial supply of the product
• contains accurate and up-to-date information
• reflects the regulatory requirements applicable in Great Britain
• is updated when relevant new information becomes available

Who must receive the SDS?

Safety Data Sheets must be provided to professional users in the supply chain.

This includes, among others:

• downstream users
• distributors
• industrial companies
• formulators
• other operators using the product during their professional activities

There is normally no obligation to provide an SDS to the end consumer, unless another legal provision requires it.

When must an SDS be updated?

An SDS is not a static document.

It must be reviewed whenever new information becomes available that could affect product safety or regulatory obligations.

Common reasons include:

• changes to the product classification
• new regulatory restrictions
• new authorisations
• changes to the composition
• new toxicological or ecotoxicological data
• changes to risk management measures
• amendments to UK REACH or GB CLP

Once updated, the new version must be provided to all new recipients moving forward, and any recipient who has received the product in the preceding 12 months.

Specific requirements for Safety Data Sheets in the United Kingdom

Language

Safety Data Sheets intended for the Great Britain market must be available in British English.

The information must be written clearly and be understandable to professional users.

Format

SDS must follow the harmonised 16-section format, which is widely recognised internationally.

The sections are:

• Other information.
• Identification.
• Hazards identification.
• Composition/information on ingredients.
• First-aid measures.
• Firefighting measures.
• Accidental release measures.
• Handling and storage.
• Exposure controls/personal protection.
• Physical and chemical properties.
• Stability and reactivity.
• Toxicological information.
• Ecological information.
• Disposal considerations.
• Transport information.
• Regulatory information.

Supplier information

Section 1 must clearly identify the party responsible for the product marketed in Great Britain.

It usually includes details such as:

• supplier name
• address
• contact telephone number
• email address, where applicable
• identified uses
• emergency telephone number

It is important to check that the contact details identify the organisation responsible for supplying the product in the GB market and are kept up to date.

Regulatory references

All regulatory references in section 15 of the SDS should refer to the UK or GB-specific legislation.

Classification and labelling

Substances and mixtures must be classified in accordance with the GB CLP Regulation. This includes meeting the mandatory classifications found in the GB Mandatory classification list (GB MCL).

Emergency telephone number

SDSs must include an appropriate emergency telephone number to enable assistance to be obtained in the event of an incident.

The company must check that the number provided meets the applicable requirements and is operational for the GB market.

It is also necessary to check the service’s operating hours and the language in which assistance is provided and provide this information as necessary on the SDS.

Updating SDSs

Safety Data Sheets must be kept up to date throughout the product life cycle.

Companies should establish internal procedures for reviewing documentation when:

• the product classification changes
• the formulation is changed
• new restrictions come into force
• new scientific data become available
• UK REACH or GB CLP evolves

Legally, any changes affecting the SDS should be implemented as soon as reasonably possible, and once a document has been updated, it must also be provided to all recipients of the product from the previous 12 months.

Great Britain and Northern Ireland: a distinction not to overlook

Due to the difficulties of administering Brexit and the specific arrangements in place for Northern Ireland, separate regulatory frameworks apply to Great Britain (England, Scotland and Wales) and Northern Ireland.

• Great Britain (England, Scotland and Wales) applies UK REACH and GB CLP.
• Northern Ireland under the Northern Ireland Protocol continues to apply EU chemical legislation, including REACH and CLP.

This means that a company marketing the same product in both jurisdictions may need to review its regulatory obligations and ensure that Safety Data Sheets and labelling comply with the legal regime applicable in each territory.

For manufacturers, importers and distributors operating across the United Kingdom, this is one of the main regulatory complexities arising after Brexit.

Differences between an EU SDS and an SDS for Great Britain

After Brexit, many companies assumed that a Safety Data Sheet (SDS) prepared under the EU REACH Regulation could be used in Great Britain.

In practice, this has proven to be problematic for many products as the EU and UK regulations have diverged. Attitudes towards acceptance of EU documents have also moved goalposts several times depending on the attitudes of the current UK political leadership.

Comparison of an EU SDS and an SDS for Great Britain

Aspect	European Union	Great Britain
Main legislation	REACH Regulation	UK REACH Regulation
Classification and labelling	CLP Regulation	GB CLP Regulation
Competent authority	ECHA and national authorities	Health and Safety Executive (HSE) Department of Environment, Food & Rural Affairs (DEFRA)
SDS format	16 sections	16 sections
Language	Official language of the Member State	British English
Regulatory references	EU legislation	UK legislation
Regulatory developments	EU updates	UK updates
Territorial scope	EU Member States	England, Scotland and Wales

Main differences in practice

Main differences between the two regions include:

• references to UK REACH instead of EU REACH, where applicable
• references to GB CLP instead of the EU CLP Regulation
• details of the supplier responsible and emergency contacts in Great Britain
• regulatory information specific to UK legislation
• differences in mandatory classifications, driven by the GB MCL and not EU Annex VI. Additionally, the UK has yet to adopt the new PBT, vPvB, PMT, vPvM and endocrine disrupting hazard classifications

Recent regulatory changes

Since leaving the EU, the UK has continued to develop its own chemical regulations, with changes often taking place at a different pace from the EU. UK policy direction can also change with a new government and its priorities. As a result, companies may face uncertainty over how and when new chemical regulations will be introduced.

Initially, due to the overnight increase in workload and the confusion caused by the Brexit process, UK authorities were slow to implement additional changes to UK regulations, causing some divergence as the EU authorities continued to progress.

In recent years, there has been a push by the competent authorities to implement changes, particularly those designed to reduce the regulatory burden placed on both industry and the government, without reducing the protection levels put in place. For example, the requirement to notify and publish a classification and labelling inventory for all substances has been removed, as the process was admin-heavy for little additional gain to either industry or the authorities.

Current political winds are pushing the UK towards closer alignment with EU chemical policies, but how far this goes and to what extent will depend on current administration actions before the next general election. For now, the UK is maintaining a separate legislative protocol, so short- and long-term divergence is expected as part of the package.

Northern Ireland continues to apply EU legislation

One of the most important regulatory points is that Northern Ireland does not apply the same legal regime as Great Britain.

Under the Northern Ireland Protocol, it continues to apply EU chemicals legislation.

This means that companies may face different regulatory obligations depending on their product’s destination within the United Kingdom.

Checklist: Does your SDS meet Great Britain’s requirements?

Before marketing a chemical product in Great Britain, it is advisable to check the following:

Requirement	Verified
The SDS meets UK REACH requirements.	☐
The classification has been reviewed under GB CLP.	☐
The SDS follows the 16-section format.	☐
Regulatory references correspond to UK legislation.	☐
Supplier details are correct for the GB market.	☐
It has been checked whether the product is also marketed in Northern Ireland.	☐
The SDS includes the latest scientific and regulatory information.	☐

This checklist is a practical tool for an initial review, but it does not replace a detailed assessment of the obligations applicable to each product.

How to keep SDS compliant in the United Kingdom

For many chemical companies, the main challenge is not preparing a single Safety Data Sheet, but keeping dozens or hundreds of For many chemical companies, the main challenge is preparing and keeping dozens or hundreds of versions of Safety Data Sheets up to date for different markets.

Brexit has added to this complexity.

The same product may require different documentation for:

• the European Union
• Great Britain
• Northern Ireland
• other international markets

As EU and UK chemical regulations evolve independently, it is increasingly important to have processes that track regulatory changes, keep documents consistent and reduce the risk of errors.

In this context, specialist solutions such as ExESS can centralise regulatory information and generate market-specific versions of Safety Data Sheets for different jurisdictions from a single database.

ExESS can also help to:

• automatically generate SDS adapted to different markets
• maintain traceability of revisions
• update documentation when regulatory requirements change
• manage multiple languages and jurisdictions
• reduce the risks associated with manually managing documents

For organisations marketing chemicals internationally, this approach helps maintain regulatory compliance and improve the efficiency of Regulatory Affairs teams.

Frequently asked questions about SDS in the United Kingdom

Can I use an SDS prepared for the European Union in Great Britain?+

A GB document must meet UK REACH requirements to be considered compliant. Although it may meet the same requirements as an EU document, this is not always the case. Each GB document must therefore be checked against the relevant UK legislation.

Which regulations govern Safety Data Sheets in the United Kingdom?+

• UK REACH Regulation, which governs the registration, evaluation, authorisation and restriction of chemical substances.
• GB CLP Regulation, which sets out the classification, labelling and packaging criteria for hazardous substances and mixtures.
• In Northern Ireland, much of EU chemicals legislation continues to apply under the Northern Ireland Protocol.

Who is the competent authority for chemicals?+

The UK chemical policy is governed by two different competent authorities.

The Health and Safety Executive (HSE) does much of the day-to-day administration of the UK chemical legislation. Its main tasks include:

• Driving UK policy on GB CLP
• Guiding the implementation of REACH/CLP and other chemical legislations
• Managing the administration of UK REACH and other regulations, including the Biocidal Product Regulations (BPR)
• Overseeing compliance with chemical legislation

However, UK REACH (alongside other chemical legislation) is under the remit of the Department of Environment, Food and Rural Affairs (DEFRA). This authority has a very wide remit, but in terms of chemical legislation, its main tasks include:

Driving UK policy on REACH and BPR legislation (among others).

What language must SDS be available in?+

Safety Data Sheets for the Great Britain market must be written in British English.

The information must be clear, understandable, and available to professional users handling the chemical product.

Is the 16-section format mandatory?+

Yes. SDS prepared under UK REACH follow the international format of 16 sections, aligned with the Globally Harmonized System (GHS).

When must an SDS be updated?+

An SDS must be updated whenever relevant new information becomes available that could affect the safe management of the product or regulatory compliance.

This may include:

• changes to the classification;
• changes to the composition;
• new toxicological or ecotoxicological data;
• new restrictions or authorisations;
• changes to UK legislation.

These changes must be implemented as soon as reasonably possible, unless the change is due to a change in harmonised classification, in which case the date stated in the GB MCL must be adhered to.

What are the main differences between an EU SDS and a UK SDS?+

At present, the most common differences relate to:

• substance restrictions
• authorisations
• hazard classifications
• regulatory references
• administrative requirements
• competent bodies

Does Northern Ireland apply the same legislation as Great Britain?+

Northern Ireland, under the Northern Ireland Protocol, continues to apply EU chemical legislation, including REACH and CLP.

This means that a company marketing the same product in both jurisdictions may need to review its regulatory obligations and ensure that Safety Data Sheets and labelling comply with the legal regime applicable in each territory.

What happens if I market chemicals in several countries?+

Each jurisdiction may set specific requirements for Safety Data Sheets.

Although many markets use the GHS as a basis, regulatory differences mean SDS must be reviewed to ensure they comply with the relevant national legislation.

Conclusion

Since Brexit, companies marketing chemicals in Great Britain should remember that the country has its own regulatory framework based on UK REACH and GB CLP.

Although these regulations are based on EU chemical regulations, they are independent. As a result, an SDS prepared for the EU market should not automatically be used in Great Britain.

In addition, a different regulatory regime is used for Northern Ireland, adding another layer of complexity for companies operating across the United Kingdom.

Keeping Safety Data Sheets up to date, periodically reviewing product classifications, and adapting documentation to each jurisdiction are essential steps to ensure regulatory compliance and reduce supply chain risks.

If your organisation manages a large volume of SDS for different markets, ExESS can help automate document generation, centralise regulatory information, and keep Safety Data Sheets up to date as each country’s requirements evolve.

How can ExESS help?

Manually managing hundreds or thousands of Safety Data Sheets for different markets can be complex and increase the risk of errors.

ExESS can centralise product regulatory information and generate SDS versions tailored to different jurisdictions, making them easier to update when legal requirements change and helping maintain consistency across documents.

Book your ExESS demo