Every chemical product on the UK market must carry a label that clearly communicates its hazards. These labels are not simply a formality—they are a legal requirement designed to protect workers, consumers, and the environment from harm. For UK-based chemical suppliers, understanding and applying the rules of the Classification, Labelling and Packaging (CLP) Regulation is an essential part of doing business in 2025.
Since the UK’s departure from the European Union, suppliers must follow the domestic version of CLP, which is closely aligned with the UN’s Globally Harmonised System (GHS) but enforced under UK-specific frameworks.
What is CLP Regulation?
The Classification, Labelling and Packaging (CLP) Regulation is the UK’s system for identifying and communicating chemical hazards. Based on the UN’s Globally Harmonised System (GHS), it requires suppliers to classify chemicals and apply standardised labels that clearly convey risks.
After Brexit, the UK adopted its own version—GB CLP—enforced by the Health and Safety Executive (HSE). While it still aligns with EU CLP in structure, updates are now handled independently, which may lead to differences over time.
CLP helps ensure that users understand chemical hazards and can take proper precautions. For suppliers, it means accurate classification, clear labelling, and regular updates to stay compliant.
Who Needs to Comply?
Any business placing hazardous chemicals on the market in Great Britain must follow CLP rules. This includes manufacturers, importers, formulators, distributors, and retailers—whether the product is for industrial or consumer use.
If you manufacture or import a substance, you are responsible for its classification and labelling under GB CLP. Importers must comply fully, even if the product was already labeled in another country. Formulators must assess and label mixtures accurately, since combined substances can present new risks.
Distributors and retailers must ensure that products remain properly labeled and must not alter hazard information. If they repackage or rebrand products, they may also be considered suppliers and take on added compliance duties.
Key Elements of a CLP-Compliant Label
Under GB CLP rules, every hazardous chemical product must have a label that includes six core elements. Each one plays a role in communicating risks clearly and ensuring safe handling:
• Product Identifiers: Include the chemical name and any relevant identification numbers, such as CAS or EC numbers. For mixtures, list all hazardous components that contribute to the classification.
• Hazard Pictograms: Use red-bordered diamond symbols that represent specific hazards like flammability, toxicity, or environmental danger. Pictograms must be clearly visible and correctly matched to the product’s classification.
• Signal Words: Use either Danger (for more severe hazards) or Warning (for less serious ones). Only one signal word is allowed per label, based on the highest level of risk present.
• Hazard Statements: Provide standardised phrases that describe the nature and severity of the hazard, such as “Causes serious eye irritation” or “Toxic if inhaled.” These must match the product’s classification and use the exact wording from the regulation.
• Precautionary Statements: Offer safety advice for prevention, response, storage, or disposal. Examples include “Keep away from heat,” “Wear protective gloves,” or “Call a poison centre if swallowed.”
• Supplier Information: Include the name, address, and phone number of the UK-based supplier. This ensures traceability and allows users to get additional support if needed.
All of these elements must be printed in English, clearly legible, and placed together on the packaging without being blocked by logos or other branding. The layout should be proportionate to the package size to ensure visibility and compliance.
UK-Specific Requirements After Brexit
Since leaving the EU, the UK has adopted its own version of the CLP Regulation, known as GB CLP, which applies in England, Scotland, and Wales. It still follows the GHS framework, but changes are now reviewed and implemented independently by the UK government. This means updates from the EU—such as new hazard categories or pictogram revisions—do not automatically apply in Great Britain.
Suppliers trading in both UK and EU markets must monitor both systems. A substance classified under EU CLP may need a different label under GB CLP, requiring businesses to maintain separate versions for different jurisdictions.
In addition to GB CLP, companies must comply with UK REACH. If a substance is being introduced to the GB market for the first time, a notification must be submitted to the HSE within one month—even if the substance was previously registered under EU REACH.
Northern Ireland remains aligned with EU CLP and REACH under the Northern Ireland Protocol. This means suppliers operating across the UK may need dual labelling to meet both EU and GB rules. Managing this split requires careful oversight and, in many cases, customised packaging strategies to stay compliant.
Common Mistakes to Avoid in 2025
Despite best intentions, many UK chemical suppliers fall short of full CLP compliance due to avoidable labelling errors. As the HSE continues to increase inspections and issue guidance updates, the risks of non-compliance grow—both legally and financially.
Here are some of the most common mistakes businesses should watch out for in 2025:
• Outdated Hazard Classifications: One of the most frequent issues is using hazard classifications that have changed. CLP hazard classes are updated regularly to reflect scientific findings. Relying on old Safety Data Sheets (SDSs) or labels without checking current classifications can lead to incorrect labelling, which could result in enforcement action or a product recall.
• Incorrect or Missing Pictograms: Pictograms are a core part of the CLP system, yet many suppliers either leave them out or choose the wrong ones. Every hazard class has a specific pictogram assigned to it. Products that meet the threshold for multiple hazards must show all applicable pictograms. Redundant symbols, however, must be avoided—only relevant icons should appear.
• Misuse of Signal Words: Only one signal word—either Warning or Danger—can appear on a label, and it must correspond to the highest level of hazard. A common mistake is including both or choosing the wrong one. This confuses users and goes against CLP labelling rules.
• Overloading or Omitting Precautionary Statements: Some labels try to include every precautionary statement related to the product, leading to visual clutter. Others skip them altogether or shorten the official wording. Both practices reduce label clarity and may result in non-compliance. The HSE allows some flexibility in prioritising the most relevant statements, but they must still be accurate and official.
• Failure to Update Imported Product Labels: Companies importing chemicals into Great Britain must update labels to meet GB CLP requirements, even if the product was correctly labeled in the EU. Many fail to add a UK supplier address, omit mandatory pictograms under GB classification, or leave the EU REACH registration code unchanged. These oversights can lead to delays at borders or fines from regulatory authorities.
Avoiding these errors requires more than a one-time check. It involves staying current with regulatory updates, auditing product lines regularly, and training staff to recognise and correct labelling issues before products reach the market.
Digital Labelling and QR Codes
As technology becomes more integrated into chemical supply chains, many suppliers are adding QR codes to product labels. These codes can link to extra safety guidance, full Safety Data Sheets, multilingual instructions, or batch traceability details. In labs and warehouses, they help staff quickly access critical information.
However, QR codes cannot replace legally required label content. All core elements—hazard pictograms, signal words, hazard and precautionary statements, and supplier details—must still appear on the physical label. The HSE has confirmed that products missing these elements are non-compliant, even if a QR code leads to the right information.
If used, QR codes should be accurate, clearly labeled, and updated regularly. They can enhance compliance but should never be used to sidestep layout rules or essential content.
Enforcement and Penalties
CLP compliance is enforced by the HSE, with support from Trading Standards and environmental authorities. Inspections can occur across the supply chain, and any mismatch between product labels and registered data may trigger action.
Failing to meet CLP labelling standards can lead to significant consequences. These include:
• Improvement or Prohibition Notices: Issued when breaches are found, requiring a business to take corrective action or halt sales of a product until issues are resolved.
• Fines: Depending on the severity of the violation, fines can reach thousands of pounds. Repeated or wilful violations may lead to criminal charges.
• Product Recalls: Non-compliant products may be removed from the market, recalled, or destroyed at the supplier’s expense.
• Reputational Damage: Publicly visible enforcement, especially recalls, can hurt a company’s brand and credibility.
Best Practices for Staying Compliant
Meeting your CLP obligations in 2025 requires more than printing the correct labels once. Regulations evolve, products change, and enforcement is increasing. To stay compliant, chemical suppliers should build CLP labelling into their regular business processes and quality controls.
1. Review Labels and Classifications Regularly
Each time a product is reformulated, imported from a new source, or affected by a regulatory update, its classification and labelling may need revision. Set a routine schedule—at least once per year—for reviewing labels against the latest guidance from HSE and international databases like the UN GHS or European C&L Inventory. Don’t rely on outdated SDSs or competitor products for reference.
2. Train Staff on Labelling Requirements
Employees handling labelling, packaging, importing, or distribution should receive regular training. This helps avoid common errors such as misused pictograms or incorrect signal words. Training sessions should cover both regulatory updates and practical examples from your product line. When everyone understands the rules, mistakes become less likely.
3. Keep Documentation in Order
Maintain updated Safety Data Sheets, classification justifications, notification confirmations, and records of label revisions. If an inspector asks for documentation, having everything on file makes it easier to demonstrate compliance and resolve any issues promptly.
4. Use Third-Party Compliance Tools
Many companies turn to digital platforms or consultants that specialise in chemical compliance. These tools can generate compliant labels based on current data, flag inconsistencies, and alert you when regulations change. They are especially helpful for businesses managing large product ranges or trading across multiple jurisdictions.
5. Prioritise Clear and Legible Label Design
Compliance depends not only on what’s written but also how it’s presented. Labels should be printed on durable materials that can withstand handling, spills, and storage conditions. Use high-contrast layouts, clear fonts, and standardised label sizes to ensure hazard information is easy to read.
6. Conduct Periodic Internal Audits
Build label checks into your broader compliance or quality assurance audits. Sample products from different batches, inspect labels against legal requirements, and document any corrections. This proactive step can prevent enforcement actions and identify gaps in your compliance process before they become liabilities.
Following these practices helps chemical suppliers maintain a high standard of safety and meet their legal responsibilities. It also builds trust with customers, partners, and regulatory bodies.
Looking Ahead: Changes and Trends
The chemical industry is shifting fast, and UK suppliers need to stay alert. Updates to the UN Globally Harmonised System may soon lead to new hazard categories in GB CLP, such as for endocrine disruptors or expanded environmental risks. Labels will likely need adjusting as these classifications evolve. At the same time, sustainability is gaining attention.
Future guidelines may push for recyclable packaging or environmental disclaimers on chemical labels. While QR codes currently serve as extras, digital labelling may play a larger role if regulators approve it for core information. AI tools are also emerging to help automate classification and flag label errors, making compliance faster and more accurate. Businesses that sell across borders should monitor any potential UK-EU harmonisation, which could reduce the need for dual labelling.
Finally, regulators are focusing more on consumer and child-targeted products, and suppliers in these areas may face stricter rules. Being proactive now can prevent expensive changes later.
