EU REACH & UK REACH, EU CLP & GB CLP – Similarities & Differences

Our private-label customers often ask us to explain what REACH is, including the difference between EU & UK REACH, especially when it comes to labelling (CLP) regulations. Here James Follows, Apollo’s Compliance Manager, explains the regulations.

James is the Chair for the Health & Safety Working Group, Vice Chair for the Environment & Sustainability Working Group and a Member of the Technical Working Group at BASA (British Adhesive & Sealant Association). He is also the UK BASA representative for the PU Training Implementation Task Force at FEICA (European Adhesive & Sealant Association).

What is EU REACH & UK REACH?

EU REACH (Registration, Evaluation, Authorisation, Restriction of Chemicals) addresses the safe production and use of chemical substances, across a wide range of sectors. It applies to the manufacturing, roofing and construction industries. In fact, it will apply to the many items you have around your home, such as cleaning products and paints, as well as materials in clothes, furniture and electrical appliances.

The focus of the regulation is chemical, and EU REACH places the duty of proof on businesses to identify and manage any risks present in the substances they manufacture and market. In short, businesses must be able to demonstrate how the substance can be used safely and they must communicate the current risk management measures to the users throughout the supply chain.

Following the UK’s withdrawal from the EU, the long-standing EU REACH Regulation was brought into the UK law under the European Union (Withdrawal) Act 2018, as UK REACH. This is separate to yet applies the same principles as EU REACH, given both systems adopt the United Nations’ Globally Harmonized System of the classification and labelling of chemicals. Under the Northern Ireland Protocol, the EU REACH Regulation continues to apply to Northern Ireland, while UK REACH provides the regulatory framework for chemicals in Great Britain.

Please visit to find a detailed article we have put together on the above and the duties business have: https://www.apolloroofingsolutions.co.uk/blog/uk-reach-and-the-roofing-industry

Is EU CLP & GB CLP the same?

As highlighted above, UK REACH has the same key principles as EU REACH. With this, GB CLP and EU CLP remain in alignment. CLP is the chemical classification system, and governs the labelling of products containing hazardous substances.

The container label content is very unlikely to change between the UK and EU classifications. If any future changes were to take place, there would be a transition period for industry to make the necessary changes in a timely manner. Apollo works closely with the relevant trade associations and would, therefore, be in a position to advise customers of any changes to regulations.

As further explanation, the UK authorities, and in particular, the Health & Safety Executive (HSE), have mirrored across the Adaptions to Technical Progress (ATP) developed over the years with the European Chemicals Agency (ECHA). This includes the most recent 14th and 15th Adaptations to Technical Progress to EU CLP, which were published and entered into force before the end of the EU Exit transition period (31st December 2020). The ATP takes into account the opinions of the Risk Assessment Committee (RAC) of the European Chemicals Agency (ECHA).

The UK authorities (HSE) still follow the detailed guidance on how to apply the agreed classification criteria provided by the European Chemicals Agency (ECHA) and advise that this should continue to be used. If evidence comes to the attention of the HSE that may lead to new or revised GB Mandatory Classification and Labelling List (GB MCL), the HSE has the scientific and regulatory expertise to prepare a GB MCL proposal.

With any proposal, the HSE will continue to monitor international forums, such as the ECHA Committee for Risk Assessment (RAC) for information that may lead to proposals for new or revised GB MCL. When a RAC opinion is published, the HSE as the GB CLP Agency, must reach an opinion of its own, regarding whether to align with RAC under the Article 37 procedure in the GB CLP Regulation.

In time, this may result in GB having a different CLP to the EU CLP for the same substance. If this was to happen, amendments will follow the similar process already in place with the EU CLP ATP and provide a timeframe (approx. 12 month) for industry to make any necessary changes to product information on the containers and Safety Data Sheet (SDS).

Looking at the GB CLP - The substances displayed on the current adhesive label are already on the GB Mandatory Classification and Labelling List (GB MCL List) and mirrors ECHA classifications.

Quick Glance Glossary:

REACH: A European Union regulation concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals. UK REACH is a replication of EU REACH, which is applicable to Great Britain only.

GHS: The GHS is a single worldwide system for classifying and communicating the hazardous properties of industrial and consumer chemicals developed by the United Nations (UN). GHS sits alongside the UN 'Transport of Dangerous Goods' system.

CLP: A European Union regulation from 2008, which aligns the European Union system of classification, labelling and packaging of chemical substances and mixtures to a Globally Harmonised System. GB CLP is a replication of EU CLP.

European Union (Withdrawal) Act 2018: An Act to repeal the European Communities Act 1972 and make other provisions in connection with the withdrawal of the United Kingdom from the EU.

HSE: The independent body responsible for health and safety policy, and the enforcement of health and safety law within the UK.

ECHA: The European Chemicals Agency, which manages the technical and administrative function of the European Union regulation, REACH.

ATP: The harmonised classification and labelling of hazardous substances is amended through an Adaptation to Technical Progress (ATP).

GB MCL: The GB Mandatory Classification and Labelling List gives information on the classification and hazard labelling of the substance and is legally binding in GB.

RAC: The ECHA committee for Risk Assessment prepares the opinions of ECHA related to the risks of substances to human health and the environment in accordance to REACH and CLP processes.