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PRACTICE NOTES
Background to the Great Britain Classification, Labelling and Packaging Regulation Trade in substances and mixtures is not only an issue relating to the market in Great Britain (GB), but also to the global market. Prior to the enactment of Regulation (EC) 1272/2008 (the EU Classification, Labelling and Packaging Regulation (EU CLP Regulation)) in 2009, harmonised criteria for the classification and labelling had already been developed at a global level within the United Nations (UN) structure, resulting in the Globally Harmonised System of Classification and Labelling of Chemicals (GHS), with a view to facilitating worldwide trade while protecting human health and the environment. The EU CLP Regulation entered into force on 20 January 2009 in the EU (then including the UK) and Recital 6 sets out the aim to contribute to the global harmonisation of criteria for classification and labelling through the incorporation of the internationally agreed GHS criteria. Classification under the EU CLP Regulation applies to substances placed on the market since 1 December 2010 and to mixtures from 1 June 2015. From 1 June 2015, the EU CLP
PRACTICE NOTES
Background to the Great Britain Classification, Labelling and Packaging Regulation Trade in substances and mixtures is not only an issue relating to the market in Great Britain (GB), but also to the global market. Prior to the enactment of Regulation (EC) 1272/2008 (the EU Classification, Labelling and Packaging Regulation (EU CLP Regulation)) in 2009, harmonised criteria for the classification and labelling had already been developed at a global level within the United Nations (UN) structure, resulting in the Globally Harmonised System of Classification and Labelling of Chemicals (GHS), with a view to facilitating worldwide trade while protecting human health and the environment. The EU CLP Regulation entered into force on 20 January 2009 in the EU (then including the UK) and Recital 6 sets out the aim to contribute to the global harmonisation of criteria for classification and labelling through the incorporation of the internationally agreed GHS criteria. Classification under the EU CLP Regulation applies to substances placed on the market since 1 December 2010 and to mixtures from 1 June 2015. From 1 June 2015, the EU CLP
PRACTICE NOTES
Background to the Great Britain Classification, Labelling and Packaging Regulation Trade in substances and mixtures is not only an issue relating to the market in Great Britain (GB), but also to the global market. Prior to the enactment of Regulation (EC) 1272/2008 (the EU Classification, Labelling and Packaging Regulation (EU CLP Regulation)) in 2009, harmonised criteria for the classification and labelling had already been developed at a global level within the United Nations (UN) structure, resulting in the Globally Harmonised System of Classification and Labelling of Chemicals (GHS), with a view to facilitating worldwide trade while protecting human health and the environment. The EU CLP Regulation entered into force on 20 January 2009 in the EU (then including the UK) and Recital 6 sets out the aim to contribute to the global harmonisation of criteria for classification and labelling through the incorporation of the internationally agreed GHS criteria. Classification under the EU CLP Regulation applies to substances placed on the market since 1 December 2010 and to mixtures from 1 June 2015. From 1 June 2015, the
PRACTICE NOTES
STOP PRESS: the Chemicals (Health and Safety) (Amendment, Consequential and Transitional Provision) Regulations 2026, SI 2026/474, revoke Chapter 2 of Title V of the GB CLP Regulation (Articles 39–42), which makes provision for notification requirements on suppliers and associated requirements for the HSE to establish and manage a publicly accessible database of the notifications it receives from 21 May 2026. Background to the Great Britain Classification, Labelling and Packaging Regulation Trade in substances and mixtures is not only an issue relating to the market in Great Britain (GB), but also to the global market. Prior to the enactment of Regulation (EC) 1272/2008 (the EU Classification, Labelling and Packaging Regulation (EU CLP Regulation)) in 2009, harmonised criteria for the classification and labelling had already been developed at a global level within the United Nations (UN) structure, resulting in the Globally Harmonised System of Classification and Labelling of Chemicals (GHS), with a view to facilitating worldwide trade while protecting human health and the environment. The EU CLP Regulation entered into force on 20 January 2009 in the EU (then including
PRACTICE NOTES
Scope of the note This note is part of a suite concerning the legal framework regulating the ecodesign of products, including the Ecodesign and Energy-Related Products Regulations 2010, SI 2010/2617 (2010 Regulations) and the Ecodesign and Energy-Related Products Regulations 2021, SI 2021/745 (2021 Regulations). This note focuses upon the ‘right to repair’ rules brought in by the 2021 Regulations, which impose obligations upon manufacturers, authorised representatives and/or importers to make certain spare parts available for certain in-scope energy related products (ErPs) and to provide repair and maintenance information to facilitate third party repair of those ErPs. The broader suite of notes includes the following: • GB Ecodesign of products—manufacturers, importers and authorised representatives • GB Ecodesign of products—responsibilities of suppliers and dealers • GB Ecodesign of products—offences, sanctions and enforcement • GB Ecodesign of products—manufacturers, importers and authorised representatives • GB Ecodesign of products—lifecycle assessment Background & relevant legislation The ecodesign regime in England and Wales was originally underpinned by the Ecodesign for Energy-Related Products Directive 2009/125/EC (2009 Directive). The 2010 Regulations (as amended)
PRACTICE NOTES
This Practice Note covers the definition and types of lifecycle assessments (LCAs) as designated under international standards including ISO 14040:2006 and ISO 14044:2006. It presents the methodology, phases and stages of LCAs before expounding the benefits and relevance of LCAs. What is a life cycle assessment? As defined by ISO 14040, life cycle assessment (LCA) is the ‘compilation and evaluation of the inputs, outputs and the potential environmental impacts of a product system throughout its life cycle’. A product system life cycle is defined in the ISO as ‘consecutive and interlinked stages of a product system, from raw material acquisition or generation from natural resources to final disposal’; this is often referred to as ‘cradle-to-grave’ analysis. Note that a product system covers both products and services. Focusing on the entire life cycle of a product/service ensures that a comprehensive and integrated assessment of all the inputs and outputs is considered and the full environmental impact of the generation of the product/service is evaluated. The goal of
PRACTICE NOTES
This Practice Note provides guidance on the obligations imposed on manufacturers, importers and authorised representatives by ecodesign legislation as well as providing details on the statutory right to repair. Ecodesign for Energy-Related Products Regulations 2010, SI 2010/2617 Ecodesign for Energy-Related Products Regulations 2010, SI 2010/2617 (as amended) (the ‘2010 Regulations’) set out the relevant bodies’ obligations regarding ecodesign in Great Britain (GB). The Ecodesign for Energy-Related Products and Energy Information Regulations 2021, SI 2021/745 set out ecodesign requirements for specific ERPs and ERP categories, and are an implementing measure for the purposes of the 2010 Regulations. The 2021 Regulations provide: • definitions for the specific ERPs considered to be in scope, • energy, resource efficiency and other product specific ecodesign requirements for those regulated ERPs, • details of the information and technical documentation required to be provided by the responsible persons for those regulated ERPs, • measurement methods and calculations for determining relevant information for the regulated ERPs, • verification procedures for post-marketing
PRACTICE NOTES
Scope of Note This Practice Note focuses on the offences, sanctions and enforcement in respect of the regulation of ecodesign and energy information in Great Britain, as set out in the Ecodesign for Energy-Related Products Regulations 2010, SI 2010/2617 (EEPR 2010) and the Ecodesign for Energy-Related Products and Energy Information (Amendment) Regulations 2021, SI 2021/745 (EEPEIR 2021), and also in the Energy Information Regulations 2011, SI 2011/1524 (EIR 2011). It provides details on the enforcement position in Northern Ireland. For further information on the application of the Northern Ireland Protocol (Windsor Framework) to environmental law, see Practice Note: What does the Northern Ireland Protocol (Windsor Framework) mean for the application of environmental law? This Practice Note is part of a suite of content on the legal regime governing the ecodesign of products, which includes the following: • GB Ecodesign of products—manufacturers, importers and authorised representatives • GB Ecodesign of products—responsibilities of suppliers and dealers • GB Ecodesign of products—lifecycle assessment • GB Ecodesign
PRACTICE NOTES
This Practice Note provides an overview of the responsibilities of suppliers and dealers in Great Britain (GB) under the ecodesign legislative regime, with a focus on the energy labelling of products. Dealers’ responsibilities under the ecodesign regime relate chiefly to energy labelling, and whilst suppliers have wider obligations as addressed briefly below, this Practice Note mainly considers the obligations of suppliers in relation to energy labelling. Note that differing obligations may apply in Northern Ireland. The main reference point for energy labelling responsibilities of suppliers and dealers is Assimilated Regulation (EU) 2017/1369 of the European Parliament and of the Council of 4 July 2017 setting a framework for energy labelling and repealing Directive 2010/30/EU (GB Energy Labelling Regulation 2017) (ELR 2017). ‘Supplier’ is defined at ELR 2017, article 2(14) as ‘a manufacturer established in GB, the authorised representative of a manufacturer who is not established in GB, or an importer, who places a product on the market’. ‘Dealer’ is defined at ELR
PRACTICE NOTES
This Practice Note provides a plain English summary of the Great Britain (GB) Balancing Mechanism, as implemented primarily under the Grid Code and the Balancing and Settlement Code (BSC). The Balancing Mechanism is a platform for trading electricity in Great Britain, used by the transmission system operator as one of its tools to ensure real time balance between electricity coming onto and coming off the transmission system. As well as giving an overview of the Balancing Mechanism and who can participate in it, this Practice Note explains the Balancing Mechanism’s context and concepts including gate closure, Balancing Mechanism bids and offers and bids and offers acceptances, and ongoing reform of the Balancing Mechanism to allow wider access. What is the Balancing Mechanism? The balancing of electricity generation and electricity consumption in close to real time is necessary to ensure the electricity system in GB operates properly and ultimately to ensure that end users receive the electricity they need. The electricity system operator (SO) is given the underlying powers and duties to ensure balancing of the system
PRACTICE NOTES
Title Assimilated Regulation (EU) 2017/1369 of the European Parliament and of the Council of 4 July 2017 setting a framework for energy labelling and repealing Directive 2010/30/EU (GB Energy Labelling Regulation) Entry into force 1 August 2017 Subject Energy labelling, energy efficiency of products In GB mandatory energy labelling is regulated by: • Assimilated Regulation (EU) 2017/1369 (the GB Energy Labelling Regulation) • Energy Information Regulations 2011 (EIR 2011) • Ecodesign for Energy-Related Products and Energy Information Regulations 2021, SI 2021/745 In-scope products have to comply with the information and labelling requirements contained therein. The EU Energy Labelling Regulation (Regulation (EU) 2017/1369) continues to apply in Northern Ireland post-Brexit. For more on the position in Northern Ireland, see Practice Note: What does the Northern Ireland Protocol (Windsor Framework) mean for the application of environmental law? DESNZ and the Office for Product Safety and Standards have produced guidance on energy information for suppliers and dealers setting out the different requirements in Great Britain and Northern Ireland. Purpose and scope of the
NEWS
Great British Energy (GB Energy) has announced their first project which is to put rooftop solar panels on around 200 schools and 200 NHS sites with the intention to save on energy bills. The savings will be reinvested in schools and NHS as part of the government’s Plan for Change to fix public services. GB Energy will also partner with community groups and the devolved governments to fund ambitious local clean power projects across the UK.