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Practical Solutions to Challenges Associated with Safety Data Sheets and Labelling in the EU-27 and the UK Following the UK Withdrawal from the EU


James Lloyd, Olena Krychevska, Adam Hedley

This work is distributed under the Creative Commons Licence Attribution 4.0 International (CC BY 4.0).

As a consequence of the UK withdrawing from the European Union, it is becoming more difficult to comply with the labelling and safety data sheet (SDS) aspects of REACH and CLP. Such difficulties have also begun to shine a light on compliance in those areas more widely across the EU – regardless of the impact of Brexit. Correspondingly, authorities are ramping up enforcement across the EU and ECHA’s Enforcement Forum is undertaking an enforcement project currently focusing on this area. Fortunately for duty holders in the EU and UK, and those exporting into those jurisdictions, the majority of the obligations are the same. Primary differences are due to legal entity changes – downstream users becoming importers, and the subsequent change this requires in legal entity details on labels and in SDS. What follows is an introduction to this issue, an outline of the obligations required in each jurisdiction, problems encountered when attempting to achieve compliance, and practical solutions to these problems. We hope that this document can be used to support your continued market access and minimise the chance of enforcement action against your business, and that of your customers.

Author details: James Lloyd, Chemical Regulatory Consultant and Brexit Lead, H2 Compliance. For correspondence: Olena Krychevska, Chemical Regulatory Consultant, H2 Compliance. For correspondence: Adam Hedley, Partner, Reed Smith LLP. For correspondence:


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