CLP Annex VIII in Great Britain: What’s the scoop?

As part of Brexit, Great Britain (GB) replaced the European Union (EU) Classification, Labelling and Packaging of Chemical Substances and Mixtures (CLP) Regulation with the GB CLP Regulation effective January 1, 2021. This meant that GB-based importers and downstream users were not obligated to submit poison centre notification to GB’s National Poisons Information Service (NPIS), but the United Kingdom (UK) Department for Health and Social Care encouraged GB entities to submit safety data sheets (SDSs) to NPIS on a voluntary basis.

…That has now changed.

In early 2022, NPIS announced that poison centre notification according to Annex VIII harmonized format is now mandatory for consumer and professional use mixtures placed on the GB market after January 1, 2021.

What we know:

  1. If you did not previously submit poison centre notifications in GB, you will now need to submit to be compliant
  2. If you voluntarily submitted any poison centre notifications since January 1, 2021, they need to be resubmitted in the Annex VIII format
  3. Safety information already submitted for Northern Ireland for an identical product sold in GB will be considered as notified
  4. If you have already notified to another EU country in the Annex VIII format, the 16Z file can be amended and submitted to NPIS
  5. NPIS is currently rejecting voluntary SDS notifications
  6. Hazardous mixtures for industrial use in the GB market do not yet need to comply with Annex VIII, but will need to be compliant by January 1, 2025.

What we don’t know yet:

  1. If unique formula identifiers (UFI)s are required on the SDS/label and/or what format they must follow
  2. If non-GB companies can submit to NPIS or if an only representative is needed
  3. If all the same criteria for poison centre notification in the EU will be mandatory in GB

 

We will be sure to keep you updated as we learn more about this developing situation, and general information and guidance pertaining to Brexit can be found on the UK government website. For questions about or assistance with your EU or GB poison centre notifications, please contact a Nexreg representative today; Nexreg and our EU partners are happy to help!