Addressing CLP and SDS challenges in post-Brexit GB
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With GB CLP replacing the EU CLP regulation, identifying the roles of suppliers is a challenge for businesses importing chemicals between the UK and the EU.
Operating independently from each other, companies that supply or purchase substances, mixtures, or articles to and from the EU/European Economic Area (EEA) and the UK now need to ensure that they meet the requirements under both the relevant UK and EU statutes.
Before January 1, 2021, a product label on a chemical imported into Germany would have been equally valid when supplied into the UK. However, products being placed on the GB market today must bear the identity of a GB-based importer/supplier.
Here are four ways to ensure your business meets requirements for both the UK and EU statutes:
Set up a Legal Entity
A popular solution for some businesses is to set up a LE in the appropriate jurisdiction that can take on the role of the supplier (manufacturer, importer, distributor or downstream user). Doing so means the LE would take responsibility for the goods.
Specify an existing importer as a 'preferred importer'
Depending on the relationship between the exporting company and importing entities, one solution is to specify an existing importer. The identity of this preferred importer can then be included on SDS and labels.
Bespoke labelling and SDS content per importing entity
By providing bespoke labelling and SDS content for each importing entity, exporting companies can reduce the "barrier to entry" for customers wishing to access those products.
Place burden of compliance on the duty holder
Whether UK or EU-based, placing the burden of compliance on the duty holder would minimize the cost to the exporter based outside of the relevant jurisdiction. This could have multiple levels:
each importer generates their CLP-compliant labels and REACH-compliant SDS
importers provide labels and SDS containing hazard information and an instruction to add a “stick-on” label containing the relevant identity and contact details
How can Yordas help?
Our team of HazCom experts can advise you on the Classification, Labelling and Packaging (CLP) requirements so you can manage your hazard communications across the globe. We can also help you address your SDS needs, from drafting or converting your texts into compliant documents as well as classifying your substances (including your mixtures), to editing, branding and translating your SDSs into more than 35 languages. Yordas Group also has the facilities to research and fill any gaps in your data
Get in touch with our team today to address areas of non-compliance for your business. You can also sign-up for our free webinar ‘CLP and SDS requirements in post-Brexit GB’ on November 16th for more insight into changes and the implications of the GB CLP.