The UK's chemicals regulatory framework may be approaching one of its most significant changes in direction since the implementation of UK REACH and GB CLP in 2020.
At the Chemical Regulation Self Help Industry Group Autumn Meeting in September 2026, the Health and Safety Executive (HSE) confirmed that a public consultation is expected to be launched on the alignment of Great Britain Classification, Labelling and Packaging (GB CLP) with the European Union's CLP Regulation.
This would reshape classification and hazard communication requirements for manufacturers, importers, downstream users and distributors supplying products into Great Britain. The change would introduce new hazard classes for endocrine disruption to human health and the environment, PBT and vPvB, PMT and vPvM substances. It would also bring updated labelling requirements with potential for digital labelling, provision for refillable container labels, and expanded use of fold out labelling.
The consultation is due to begin imminently with a target to implement the legislation by Autumn 2027. Businesses operating across UK and EU markets should consider compliance and supply chain implications now.
Why is GB CLP alignment being considered?
Since the UK's departure from the European Union, GB CLP and EU CLP have progressively diverged. For many organisations operating across both jurisdictions, divergence creates additional complexity. Separate classification assessments, labelling requirements, compliance processes and regulatory monitoring activities increase both compliance costs and administrative burden. Greater alignment may help simplify these requirements for businesses active in both markets while supporting consistency in hazard communication and supply chain management.
However, alignment also introduces new obligations that many companies will need to assess carefully.
Which new hazard classes could be introduced to GB CLP?
The anticipated consultation is expected to include adoption of the additional hazard classes already incorporated within the EU CLP framework:
- Endocrine disrupting to human health and the environment
Substances capable of adversely affecting endocrine systems in humans or the environment.
- Persistent, Bioaccumulative and Toxic (PBT) properties
Substances that remain in the environment, accumulate in organisms and exhibit toxic effects.
- Very Persistent and Very Bioaccumulative (vPvB) properties
Substances that are both highly persistent and accumulate heavily in organisms creating concerns for long-term pollution in the environment
- Persistent, Mobile and Toxic (PMT) properties
Substances capable of spreading rapidly through environmental compartments such as groundwater while maintaining persistence and toxicity.
- Very Persistent and Very Mobile (vPvM) properties
Substances that are both highly persistent and highly mobile, creating potential concerns for drinking water resources and long-term environmental exposure.
The consultation will also consider recent amendments to labelling requirements under EU CLP, although aspects of these provisions continue to evolve within the EU. There will certainly be inclusion of digital labelling options, and new requirements for refillable container labels. We may also see label formatting requirements being introduced.
What could this mean for businesses?
While the precise scope and implementation timetable remain subject to consultation, businesses should be aware that alignment to EU CLP and adoption of the new hazard classes could trigger a wide range of compliance activities for GB products.
Potential areas requiring review include:
- Substance and mixture classifications
- Safety Data Sheets (SDSs)
- Product labels and packaging
- Supplier and customer communications
- Product stewardship programmes
- Regulatory compliance strategies
- Supply chain due diligence processes
For some organisations, particularly those with large product portfolios or extensive supply chains, preparation and implementation could require significant time and resource.
Why should industry engage in the GB CLP consultation?
The consultation will provide businesses with an opportunity to influence how any future alignment and transition measures are implemented in Great Britain. Practical challenges associated with data availability, classification methodologies, implementation timelines and supply chain impacts are likely to be important topics of discussion.
Engagement from industry stakeholders will help ensure that regulatory objectives can be achieved while maintaining a proportionate and workable compliance framework for businesses operating in Great Britain.
What should companies be doing to prepare for GB and EU CLP alignment?
The HSE has indicated that the consultation is expected in the near future, with legislation potentially intended to be in place by Autumn 2027. While the final shape of any regulatory changes remains uncertain, organisations should begin monitoring developments closely. Businesses with products placed on both UK and EU markets may be particularly affected by any changes to classification and hazard communication requirements.
The coming months are likely to generate significant discussion across industry, trade associations and regulatory bodies as stakeholders consider the implications of greater alignment between GB CLP and EU CLP.
Organisations that begin assessing potential impacts now will be better positioned to respond as consultation activities commence. To understand more about the implications for your product portfolio, please get in touch.
