contexts
The Classification, Labeling and Packaging (CLP) Regulation (EC) No 1272/2008, based on the United Nations' Globally Harmonized System (GHS), aims to ensure a high level of protection of health and the environment, as well as the free movement of Substance, Mixture and Article.The CLP Regulation amends the Dangerous Substances Directive (67/548/EEC (DSD)), the Dangerous Preparations Directive (1999/45/EC (DPD)) and parts of the European Union's Dangerous Preparations Directive (1999/45/EC (DPD)) and the European Union's Dangerous Preparations Directive. Dangerous Substances Directive (67/548/EEC (DSD)), the Dangerous Preparations Directive (1999/45/EC (DPD)) and part of the European Union Regulation on the Registration, Evaluation, Authorization and Restriction of Chemicals (EC) No 1907/2006 (REACH)), and, since June 1, 2015, it has become the only legislation on the classification and labeling of chemicals and mixtures that is enforced within the EU. mixtures classification and labeling legislation within the EU.
CLP is legally binding in the European Economic Area (EEA) and is directly applicable to all industries. It requires manufacturers, importers or downstream users to properly classify, label and package hazardous substances or mixtures before placing them on the market.
Scope of Application and Classification
1. Scope of Application
CLP applies to all substances and mixtures placed in the European Economic Area (EEA), unless there are more specific requirements laid down in other legislation, such as.
- (a) Drugs as defined in Regulation (EC) No 726/2004;
(b) Veterinary products as defined in Regulation (EU) 2019 / 6;
(c) Cosmetics as defined in Regulation (EC) No 1223/2009;
(d) medical devices that are invasive or used for direct physical contact with the human body, as defined in Regulation (EU) 2017/746, and medical devices as defined in (EU) 2017/745;
(e) Food or feed as defined in Regulation (EC) No 178/2002, including:
Food additives within the scope of Regulation (EC) No 1333/2008;
Food flavoring agents within the scope of Regulation (EC) No 1334/2008;
Animal nutrition products within the scope of Regulation (EC) No 1831/2003;
2. Hazard classification
The hazard categories defined in the CLP regulation include physical, health, environmental and other potential hazards, and one of the core objectives of CLP is to assess whether a chemical substance or mixture possesses the characteristics that cause it to be classified as a particular hazard category. Within this framework, hazard classification forms the basis for hazard communication. Whenever relevant information (e.g. toxicological data) about a chemical substance or mixture meets the classification criteria of CLP, it is assigned a corresponding hazard class and label, which identifies and communicates its potential hazardousness.
2.1 Existing Classification Criteria
Hazard classification of chemical substances or mixtures is required by manufacturers, importers or downstream users:
- Classification of Chemical Substances
Unify the categories:
For the risk categories of greatest concern, such as carcinogenicity, mutagenicity, toxicity for reproduction (CMR) and respiratory sensitization, as well as for other specific substances, the EU has implemented a harmonized classification and labelling system to ensure proper risk management. This system is implemented through the Common Classification and Labeling (CLH) regulations. For substances that have already been classified (see Annex VI of the CLP Regulation), the CLH has the force of law with regard to the types of hazards involved and the differences in classification, and all enterprises producing, importing or acting as downstream users must comply with the classification criteria. Meanwhile, distributors can also refer to the C&L Inventory database for information on the classification of specific chemical substances and mixtures. However, it should be noted that the European Chemicals Agency (ECHA) does not verify the accuracy of such data, and distributors can further consolidate the information from other data sources (e.g., ECHA Registered Substances Database and GESTIS Substances Database) or consult third-party professional organizations for further verification. The data are not verified by ECHA.
Self-categorization:
If a CLH entry does not include a specific hazard class or there is a classification discrepancy, you are responsible for making an independent assessment and self-categorizing. In the case of self-classification (in addition to following the standardized classification criteria in Annex VI of the CLP Regulation), you must ensure that your classification decisions are reasonable and well-founded and, where possible, are made in consultation with other manufacturers, importers or downstream users. - Classification of chemical mixtures
Chemical mixtures are required to classify themselves before placing them on the market as they are not subject to the Uniform Classification and Labeling (CLH). For guidance on classification of mixtures, please refer to: https://echa.europa.eu/support/mixture-classification. It is important to note that there are special supplementary information requirements for some specific chemical mixtures, please refer to the following labeling requirements for details.
2.2 New Categorization Standards
From April 2023, the EU has implemented new hazard classifications and standards. These new rules apply to all chemical substances and mixtures placed on the EU market, including biocide products and active substances in plant protection products, under the REACH and CLP regulations. The implementation of these new rules includes a transition period to ensure that market participants have sufficient time to comply with the new requirements. - For new chemicals, new classification, labeling and packaging regulations must be met from May 1, 2025 onwards.
- For chemicals already on the EU market, they will need to comply with the new regulations by November 1, 2026.
- For the new chemical mixtures, the new rules will be effective May 1, 2026
- For chemical mixtures already on the market, they must comply with the new regulations by May 1, 2028.
Sellers and suppliers need to understand and adapt to these new classification standards in a timely manner to ensure that their products comply with the new legal requirements. To ensure compliance, sellers are advised to pay close attention to the latest information and guidelines issued by ECHA and prepare corresponding adjustments to meet the new regulatory requirements. Refer to New hazard classes 2023
Labeling and Packaging Requirements
Having completed the classification of a chemical substance or mixture, there is a real need to communicate the identified hazards to the entire supply chain, including the consumer, through appropriate labeling and Safety Data Sheets (SDS). This is to ensure that all those who may come into contact with or use these chemicals are aware of their potential hazards and that appropriate measures are taken to manage these risks. clp sets detailed standards for hazard labeling elements, with corresponding hazard pictograms, signal words, hazard statements and precautionary statements for each hazard class and category. the clp regulations also set general packaging standards to ensure safe The CLP regulations also set general packaging standards to ensure the safe supply of hazardous substances and mixtures.
1. Labeling requirements
1.1 General Requirements:
The CLP regulation requires that the label must be securely affixed to one or more surfaces of the immediate container of the chemical substance or mixture and that the contents of the label must be readable horizontally when the package is in its normal position. The label elements themselves, especially the hazard pictograms, must be clearly visible from the background. In addition, the size and spacing of all label elements must be easily readable, and the markings must be clear and indelible. Additional physical labeling is not required when the labeling elements are clearly displayed on the package itself.
The label must contain the following information:
- Name, address and telephone number of the supplier; (see CLP Guidance clause 4.1 for specific format)
- The nominal quantity of the substance or mixture in the package available to the public (unless the quantity is specified elsewhere on the package);
- Product Identifiers: The label should include details of the substance or mixture for which identification is permitted. (See CLP Guidance 4.2 for specific format.)
- Hazard pictograms, signal words, hazard statements, precautionary statements, and other supplemental information required by statute are labeled according to the actual hazard classification.
The CLP regulation also requires labels to be written in the official language of the destination market, unless otherwise specified by the relevant member country. Traders can refer to Languages required for labels and safety data sheets to determine which languages are required.
1.2 Hazardous labeling content:
1.2.1. Hazard Pictogram Icon - The latest hazard pictogram icon has the shape of a red diamond on a white background. You can refer to the following icons according to the hazard classification correspondence. For more information, refer to "Explanation of Hazard Pictograms" and CLP Guidance Section 4.3.
1.2.2. Labels not only display pictograms but also provide corresponding "hazard statements" to explain the meaning of the pictograms. A pictogram may correspond to a number of hazard statements which detail the different risks that may be posed by the substance or mixture in question. For example, an exclamation mark may indicate that the substance can cause respiratory irritation, severe eye irritation, or skin irritation.
1.2.3. A "precautionary statement" is also required to be provided on the label to instruct the user on how to handle the product safely and what to do after accidental contact.
1.2.4. Risk levels are indicated on labels by "signal words", where "Danger" indicates high risk and "Warning" indicates lower risk. Warning" indicates a lower risk.
1.2.5 The label may also contain "supplementary information", which is categorized into mandatory and non-mandatory information. Mandatory information includes EUH declarations (e.g., EUH014 "reacts strongly with water"), Unique Formulation Identifier (UFI), and other requirements set out in EU regulations; non-mandatory information is usually related to the use and handling of the product, e.g., "Read the label before use" or "Avoid contact with eyes. Non-required information is usually related to the use and handling of the product, such as "Read label before use" or "Avoid contact with eyes".
Hazard pictograms, signal words, hazard statements, precautionary statements, and other supplemental information required by the statute have specific forms of representation, as described in the CLP Statute Annex, or refer to CLP Guidance Sections 4.4-4.8.
For certain specific chemical mixtures, CLP Part 2 of Annex II specifies corresponding content requirements, for example:
- For mixtures containing isocyanates, additional information is required EUH204 - "Contains isocyanates. May produce an allergic reaction".
- For adhesives containing Cyanoacrylate, the specified description should be used on the packaging EUH202 - 'Cyanoacrylate. Danger. Bonds skin and eyes in seconds. Keep out of the reach of children'.
- For paint coatings containing more than 0.15% of lead, use the description EUH201 - 'Contains Lead. Should not be used on surface liable to be chewed or sucked by children', if the lead content is less than 125ml, use EUH201A 'Warning! Should not be used on surface liable to be chewed or sucked by children', if the lead content is less than 125ml, use EUH201A 'Warning!
Label Example.
1.3 Alternative names in chemical mixtures
In order to maintain the confidentiality of formulations, chemical manufacturers, importers and downstream users in the EU can apply for the use of alternative chemical names to avoid disclosing the detailed composition of the mixture on labels or Safety Data Sheets (SDS). However, the use of alternative names is subject to specific conditions, including:
- Substances applied for are not subject to community workplace access restrictions.
- The use of alternative names provides sufficient information to ensure that the necessary health and safety precautions can be taken in the workplace and that the risks of the operational mixture are reasonably controlled.
- The substance under application can only belong to a specific hazard class listed in Annex I - Part 1.4.1 (III) of the CLP Regulation.
The adoption of alternative chemical names is subject to fees under CLP regulations, which vary depending on the size of the company and the amount of mixture involved in the application.
1.4 Labeling Content Exemption
The CLP Regulation provides specific labeling exemptions for small-volume packages (e.g., less than 125 milliliters) or for substances and mixtures that are difficult to label. Examples of specific exemptions can be found in Annex I, Section 1.3 of the CLP Regulation. These special provisions allow suppliers to omit labeling elements such as hazard statements, precautionary statements, or hazard pictograms from labels that would normally be required.
2. Packaging requirements:
Clause 35 of the CLP contains requirements for packaging containing hazardous substances or mixtures. Hazardous chemical packaging must be designed, constructed and fastened in such a way that the contents cannot escape at any time. Therefore, the packaging material must be strong, rigid, and able to resist damage to the contents. Replaceable fastening devices must be able to be re-tightened repeatedly without causing the contents to escape. Packaging of chemicals available to the public must not attract, arouse the curiosity of children, or mislead consumers. The packaging must not have a similar appearance or design as that used for food, animal feed, medicine or cosmetics. Child safety fasteners (CRFs) and/or tactile hazard warnings (TWDs) must be used if the chemical or mixture is available to the public and exhibits certain hazards, or if the product contains methanol or methylene chloride.
In addition, disposable laundry gels require additional safety measures to make the packaging unattractive to children and more difficult to open, as well as warnings on the packaging reminding parents and caregivers that these products must be kept out of the reach of children, as described in CLP Article 35(1)(2) and Appendix II, Section 3.3.
Compliance Requirements
Goods destined for the EEA are required to comply with CLP labeling and packaging requirements, and non-compliant goods cannot be sold into the EEA.
Please note that this rule only lists the key contents of the CLP regulation guidelines, more details need to be referred to the CLP regulation and CLP Guidance for merchants to understand, and combined with your actual goods labeling and packaging design, you can also contact the Green Circle to seek CLP labeling and packaging compliance support.
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