Since Brexit, the UK operates under two sets of chemical regulations. In Great Britain (England, Scotland and Wales), safety data sheets must comply with UK REACH, and classification with GB CLP. In Northern Ireland, EU REACH and EU CLP remain in effect. Products sold throughout the UK may require both a GB SDS and an EU-format SDS.
The GB SDS keeps the same 16 sections as the EU SDS, with required content in each section. Suppliers must provide it free of charge with the first delivery and update it without delay. The key differences are who counts as the supplier, which classifications and exposure limits apply, and which EU rules GB has or has not adopted since 2021.
Last reviewed November 7, 2026. This page provides information only and does not constitute legal advice.
Great Britain vs. Northern Ireland
| Great Britain | Northern Ireland | |
|---|---|---|
| SDS rules | UK REACH Article 31 and Annex II | EU REACH Article 31 and Annex II |
| Classification and labels | GB CLP, including the GB mandatory classification list (GB MCL) | EU CLP, including EU harmonised classifications |
| Regulator | HSE, with Defra leading on UK REACH | HSENI, with EU rules |
| Poison centre notification and UFI | Not required | Required, as in the EU |
| SDS language | English | English |
For Northern Ireland, follow our EU SDS requirements guide. The rest of this page covers Great Britain.
GB SDS vs. EU SDS: what changes
Most of a GB SDS matches the EU version. These are the points to change when you adapt an EU SDS for Great Britain.
| Topic | Great Britain | EU |
|---|---|---|
| Supplier in Section 1 | A GB-based manufacturer, importer, downstream user or distributor | An EU-based supplier |
| Language | English | Official language of each country of sale |
| Classification | GB CLP and the GB MCL list, which can differ from EU harmonised classifications for the same substance | EU CLP and Annex VI harmonised classifications |
| New hazard classes | GB CLP has not adopted the EU’s endocrine disruptor, PBT/vPvB or PMT/vPvM classes | Required for substances and mixtures on a phased schedule to May 1, 2028 |
| Section 3 | UK REACH registration numbers, which differ from EU numbers | EU REACH registration numbers |
| Section 8 | GB Workplace Exposure Limits from HSE’s EH40 | EU indicative limits and national limits of each country |
| Section 15 | GB regulations, such as COSHH and UK REACH | EU regulations, such as REACH authorisation and restriction |
| UFI | Not used; no poison centre notification | Required on the label of mixtures classified for health or physical hazards |
| Confidential ingredient names | Alternative chemical name requested from HSE | Alternative chemical name requested from ECHA |
Some rules are the same in Great Britain and the EU. In both:
- You must give your customer the SDS free of charge, on paper or electronically, no later than the first delivery.
- When you learn something new about the product’s hazards or how to control them, you must update the SDS without delay.
- You must send the updated SDS to every customer you supplied in the previous 12 months, not only to new customers.
What goes in each of the 16 sections is also largely the same. See our EU SDS requirements guide for the section-by-section detail.
GB CLP changes in 2026
The Chemicals (Health and Safety) (Amendment, Consequential and Transitional Provision) Regulations 2026 changed GB CLP. According to HSE:
- Effective May 21, 2026, manufacturers and importers are no longer required to notify HSE of the classification and labelling of substances placed on the GB market. Northern Ireland businesses supplying the Northern Ireland market must continue to notify ECHA.
- GB mandatory classifications will transition to a new adoption system. The current system remains in place during the transition period.
GB and EU classifications may diverge as each adopts its own mandatory classifications. The same substance may be classified differently in GB and the EU. Always verify each SDS against the list for its own market.
How Valenc handles the UK
Valenc generates GB and EU SDSs from a single product record, ensuring consistency for products sold in Great Britain, Northern Ireland and the EU.
- Separate GB and EU classification: Valenc’s rules engine applies GB CLP and EU CLP independently, identifying any differences in classification.
- GB exposure limits: Section 8 lists GB Workplace Exposure Limits.
- GB labels: labels are generated from the same classified record used for the GB SDS.
- One change, every version flagged: when a formulation or rule changes, every affected US, GB and EU SDS is flagged for review.
- Your approval before publication: your team reviews and approves each SDS prior to release.
View supported regions and languages, or request a demo with one of your products.
Frequently asked questions
Is a UK SDS the same as an EU SDS?
Both use the same 16-section format, but a GB SDS requires a GB supplier, GB CLP classification, GB Workplace Exposure Limits, UK REACH registration numbers and GB regulatory information. Northern Ireland follows EU rules.
Does a GB SDS need a UFI?
No. Great Britain does not require poison centre notification. Northern Ireland follows the EU and does require it.
What exposure limits go in Section 8 of a GB SDS?
GB Workplace Exposure Limits from HSE's EH40.
Has GB adopted the EU's new hazard classes?
No. The endocrine disruptor, PBT/vPvB and PMT/vPvM classes added to EU CLP in 2023 are not included in GB CLP.
Do I still notify HSE of classifications?
No. The GB notification requirement ended on May 21, 2026.
Sources
- Changes to the GB CLP Regulation, HSE
- Safety data sheets, HSE
- Requesting the use of an alternative chemical name for the GB market, HSE
- REACH safety data sheets, HSENI
See a GB SDS and an EU SDS built from one of your own products, from the same record as your US SDS.
