On January 26, 2026, the UK Health and Safety Executive (HSE) submitted a Technical Barriers to Trade (TBT) notification to the World Trade Organization (WTO), proposing amendments to the Great Britain Mandatory Classification and Labelling List (GB MCL List). The proposal seeks to impose new mandatory classification and labeling requirements for 60 hazardous chemical substances.
Background
Following its formal departure from the European Union on January 1, 2021, Great Britain (GB)—comprising England, Scotland, and Wales—no longer adheres to the European Union’s Regulation on the Classification, Labeling and Packaging of Substances and Mixtures (CLP Regulation), enacted on December 16, 2008. Instead, the UK has established its own GB CLP Regulation, based on the EU CLP framework, and developed a national Mandatory Classification and Labelling List (GB MCL) for chemicals.
Specific classification recommendations for the 60 substances can be accessed via the following link:
https://members.wto.org/crnattachments/2026/TBT/GBR/26_00503_00_e.pdf
Obligations under the GB MCL List
- Substances listed in the GB MCL must adopt the mandatory classification and labeling specified in the list.
- For mixtures containing substances included in the GB MCL, mandatory classification criteria must be applied during assessment—unless reliable scientific data on the mixture itself is available to allow direct classification without relying on information about its constituent substances.
Stakeholders may submit comments by March 27, 2026. The regulation is expected to be formally adopted in the second quarter of 2026. Companies may voluntarily comply with the new standards ahead of the full mandatory implementation, which is scheduled for the fourth quarter of 2028.
