A label without contact details of an EU legal entity is not compliant with CLP. According to Article 17(1)a, a substance or mixture classified as hazardous and contained in packaging must bear a label including the name, address, and telephone number of the supplier(s). By definition, a ‘supplier’ means any manufacturer, importer, downstream user or distributor placing on the market a substance, on its own or in a mixture, or a mixture, and each of these entities is defined as a natural or legal person established within the Community (Article 2 CLP).
Therefore, the required change of the contact details from a United Kingdom-based to an EU/EEA-based supplier is not considered as an update of the label (according to Article 30 CLP), but as a pre-requisite for the placing of substances and mixtures on the EU/EEA-market. This applies through the entire supply chain.
In practice, and in line with provision TBT.8 on marking and labelling in the Trade And Cooperation Agreement between the European Union and The United Kingdom Of Great Britain And Northern Ireland (as published on 31 Dec 2020), it is acceptable to use a sticker with the EU supplier’s details to cover those of the non-EU supplier. Before labels are updated due to other reasons, each supplier in the supply chain needs to add such stickers on the products they supply, with their own or their supplier’s contact details.
It can also be noted that labelling, including supplementary labelling or corrections to labelling, may take place in customs warehouses or other designated areas in the country of import as an alternative to labelling in the country of origin, unless such labelling is required to be carried out by approved persons for reasons of public health or safety.
For information on whether the non-EU supplier's contact details can be included in the label, see Q&A 1808.