Importing chemicals from the UK to Poland – UK REACH, CLP, SDS and DG classification

Q: How do I check whether a UK substance is registered in EU REACH?

You can search the ECHA database (echa.europa.eu) by substance name, CAS number, or EC number. If the substance is registered, check whether the scope of registration covers your volumes and uses.

Q: Are chemicals from the UK subject to CBAM?

CBAM in its current phase covers only cement, aluminium, steel, fertilisers, electricity and hydrogen. The majority of chemicals in HS28-38 are not subject to CBAM, although the scope may be extended in future.

Importing chemicals from the United Kingdom to Poland is one of the most heavily regulated areas of cross-border trade. Since Brexit, trade in chemical substances between the UK and the EU is governed by two separate regulatory frameworks — EU REACH on the Polish side and UK REACH on the British side. Despite sharing a common origin (both grew out of Regulation EC 1907/2006), they now operate as distinct, independent legal regimes. Compliance errors in this area can result not only in goods being held at the border, but also in civil and criminal liability for the importer for placing non-compliant substances on the market. This article covers all the key aspects of importing chemicals from the UK in detail: the differences between UK REACH and EU REACH, Safety Data Sheet (SDS) requirements, CLP classification and labelling, ADR dangerous goods transport classes, customs documents for HS28–38, and applicable duty rates. Essential reading for every importer and procurement team working with UK chemical suppliers.

UK REACH vs EU REACH — two separate systems after Brexit

Before Brexit, a single EU REACH system covered both the UK and the entire EU. Since 1 January 2021, two separate systems have been in operation:

EU REACH (Reg. EC 1907/2006 + updates)

Administered by ECHA (European Chemicals Agency, Helsinki)
Covers all 27 EU member states + EEA (Norway, Iceland, Liechtenstein)
Registration of substances at ≥1 tonne/year is mandatory for manufacturers/importers into the EU
SVHC (Substances of Very High Concern) candidate list — updated annually
Restrictions on use of substances in Annex XVII
Authorisation for particularly hazardous uses (Annex XIV)

UK REACH (UK Chemical Regulations 2021)

Administered by HSE (Health and Safety Executive, Great Britain)
Applies only in England, Wales and Scotland (Northern Ireland follows EU REACH)
Separate registration database: UKREACH.HSE
UK SVHC list — initially identical to the EU list, but may diverge over time
Importers into the UK from the EU must complete a "downstream user import notification" or register under UK REACH

What does this mean for a Polish importer?

Aspect	Obligation on the UK side (exporter)	Obligation on the PL side (importer)
Substance registration	UK REACH (HSE) — applies in the UK	EU REACH (ECHA) — applies in Poland
SDS compliant with	UK CLP — required in the UK	EU CLP (Reg. 1272/2008) — required in Poland
SVHC list	UK SVHC (HSE)	EU SVHC (ECHA) — importer must verify
Authorisation	UK Auth — for the UK market	EU Auth — for the EU market

Key takeaway: your UK supplier may be fully compliant with UK REACH and UK CLP, but an SDS issued in the UK may not meet all EU requirements. As an importer into Poland, you are required to hold an SDS that complies with EU Reg. 1907/2006 and EU CLP 1272/2008.

SDS (Safety Data Sheet) — EU requirements vs documents from the UK

An SDS is a chemical safety data sheet — a 16-section document required when trading in hazardous substances and mixtures. After Brexit, the UK adopted its own SDS format compliant with UK CLP, which is very similar to, but not identical with, EU CLP.

What may differ in a UK SDS vs EU requirements: - REACH registration number — a UK SDS will carry a UK REACH number, not an EU REACH number. When importing into Poland, you need the EU REACH registration number (where the substance is registered) - Emergency contact number — UK: 0800 404 7261; Poland: an EU/PL-appropriate number is required (e.g. a Toxicological Information Centre) - Language — the SDS must be in Polish (or the language of the destination country) in accordance with REACH Reg. Art. 31 - CLP classification — UK CLP and EU CLP classifications may diverge for certain substances where divergent updates have occurred since 2021

Practical advice: always request from your UK supplier an EU-compatible SDS in Polish or English (English is acceptable where the importer is a professional, but the Labour Inspectorate may require Polish for employees).

CLP — classification and labelling of chemicals

EU CLP (Classification, Labelling and Packaging) — Reg. 1272/2008 — sets out the rules for classifying, labelling and packaging chemical substances and mixtures in the EU.

For a Polish importer this means: - The label on packaging of chemicals imported from the UK must comply with EU CLP, not UK CLP - If the label is in UK format only, you must repackage or apply an additional EU CLP label before placing the goods on the EU market - GHS pictograms on UK labels are identical to EU ones (both use the UN GHS system), but other label elements may differ

Mandatory elements on an EU CLP label: 1. Name of the substance or mixture (identifier) 2. Index number(s), CAS, EC 3. GHS pictograms 4. Signal words: "Danger" or "Warning" 5. H (hazard) and P (precaution) statements 6. Details of the manufacturer/importer responsible for the EU 7. Net contents

ADR transport — dangerous goods classification

Many chemicals are classified as dangerous goods (DG) for road transport under the ADR Agreement.

Main ADR classes for chemicals:

ADR Class	Hazard type	Examples of chemicals
Class 2	Gases	Compressed technical gases, aerosols
Class 3	Flammable liquids	Solvents, paints, fuels
Class 6.1	Toxic substances	Pesticides, acids, aldehydes
Class 8	Corrosive substances	Sulphuric acid, sodium hydroxide
Class 9	Miscellaneous substances	Environmentally hazardous substances

When transporting DG from the UK to Poland, the following are required: - Correct marking of containers and the vehicle (ADR labels/placards) - Dangerous Goods Declaration (DGD) or CMR with ADR notation - Driver ADR training certificate - Written instructions (emergency written instructions per ADR) - Correct segregation of ADR classes during loading

Customs duties HS28–38 — chemicals from the UK

HS chapters 28–38 cover a broad range of chemical products:

HS Chapter	Contents	Typical MFN rate	TCA (UK origin)
HS28	Inorganic chemicals, precious metals	0–5.5%	0%
HS29	Organic chemical compounds	0–6.5%	0%
HS30	Pharmaceutical products	0%	0%
HS31	Fertilisers	0–6.5%	0%
HS32	Dyes, paints, varnishes	0–6.5%	0%
HS33	Cosmetics, perfumes	0–6.5%	0%
HS34	Soaps, cleaning agents, waxes	0–6.5%	0%
HS35	Adhesives, enzymes	0–6.5%	0%
HS38	Miscellaneous chemical products	0–6.5%	0%

For chemicals of UK origin under the TCA, the rate is 0%, provided the rules of origin are met. For synthetic chemicals the rule is typically "wholly obtained" or "manufactured from" (synthesis in the UK).

SCIP notification obligation (ECHA)

For importers into the EU — the SCIP obligation (Substances of Concern In articles, Products): if you import articles (not substances) containing SVHC substances above 0.1% by weight, you must notify the SCIP database maintained by ECHA.

This applies to imports including: - Plastic articles containing SVHC substances - Coated metal components - Adhesives and sealants containing SVHC substances

SCIP notification is submitted electronically via the ECHA portal and is free of charge. Failure to notify constitutes a breach of the Waste Framework Directive (WFD 2008/98/EC as amended).

Practical step-by-step guide to importing chemicals from the UK

Identify the goods — chemical name, CAS number, CN code (HS28–38)
REACH verification — check whether the substance is registered in EU REACH (ECHA database). If you are the first importer, you may have an obligation to register or join an existing dossier
Obtain the SDS — request an EU-compatible SDS from the supplier (or EU-adapted version)
SVHC check — is the substance on the ECHA SVHC list?
DG classification check — is the goods classified as ADR?
Arrange transport — if DG, ensure ADR compliance (packaging, documents, marking)
Customs clearance — customs declaration with the correct CN code, value, and TCA documents
Storage — ensure the warehouse meets the requirements for chemical substances (fire safety, H&S)

Customs documents for chemical imports from the UK

Document	Issued by	Notes
Commercial invoice	UK exporter	Chemical name, CAS, UN number (if DG)
UK Origin Statement / REX	UK exporter	For 0% TCA rate
CMR	Carrier	With ADR notation if DG
SDS (EU-compatible)	UK manufacturer	16 sections, EU CLP, Polish or English language
DGD (Dangerous Goods Declaration)	Sender	If DG/ADR
REACH registration confirmation	Manufacturer/importer	If the substance requires EU registration
CoA (Certificate of Analysis)	UK manufacturer	Purity, technical parameters

FAQ

Is an SDS issued in the UK valid for import into Poland? Not directly — an SDS from the UK complies with UK CLP, but may not meet all EU REACH/EU CLP requirements. As an importer into Poland, you must hold an SDS compliant with EU law (Reg. 1907/2006 + 1272/2008). Request an EU-market version of the SDS from your UK supplier.

What does it mean to be an "importer" under EU REACH? An importer under EU REACH is any natural or legal person in the EU who brings chemical substances from a third country (including the UK after Brexit). If you import a substance at ≥1 tonne/year, you may have an obligation to register or notify ECHA, unless you benefit from an existing registration via an "only representative" importer.

How do I check whether a UK substance is registered in EU REACH? You can search the ECHA database (echa.europa.eu/information-on-chemicals/registered-substances) by substance name, CAS number, or EC number. If the substance is registered, check whether the scope of registration covers your volumes and uses.

Are chemicals from the UK subject to CBAM? CBAM (Carbon Border Adjustment Mechanism) in its current implementation phase (2023–2025) covers only: cement, aluminium, steel, fertilisers, electricity and hydrogen. From 2026 the scope may be extended, but the majority of chemicals in HS28–38 are not subject to CBAM.

Which ADR classes are most common when importing chemicals from the UK? The most common ADR classes for UK chemical imports are: Class 3 (flammable liquids — solvents, paints), Class 8 (corrosive substances — acids, bases) and Class 6.1 (toxic substances). Each class requires specific UN-certified packaging and documentation.

How much does customs clearance for chemicals from the UK cost? An import clearance for chemicals from the UK typically costs from £45 to £150 per shipment. ADR loads may cost more due to additional procedures and REACH documentation. The exact quote depends on the number of commodity lines and the complexity of the documentation.

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