The Classification, Labelling and Packaging (CLP) Regulation ((EC) No 1272/2008) is based on the United Nations’ Globally Harmonised System (GHS) and its purpose is to ensure a high level of protection of health and the environment, as well as the free movement of substances, mixtures and articles.

CLP is directly applicable and binding across the EU. It applies to all substances and mixtures, placed on the EU market, with the exception of those listed in Article 1, paragraphs 2 to 5 of CLP. Suppliers (manufacturers, importers, downstream users, and distributors) of substances and mixtures, all have general and specific obligations depending on their role, under CLP. Hazardous substances and mixtures placed on the EU market must be classified in accordance with CLP, and the labelling and packaging rules of CLP must be followed. To ensure that correct CLP label information and safe packaging reaches the final user, the whole supply chain needs to co-operate.

CLP revisions

The CLP Regulation was significantly revised in 2023, with the inclusion of new hazard classes (Commission Delegated Regulation (EU) 2023/707), entry into force on 20 April 2023.

Another significant revision took place in 2024, with new and amended provisions being included, covering a range of subjects from classification, labelling and packaging (Regulation (EU) 2024/2865). However, not all the new and amended provisions apply from the entry into force, 10 December 2024 but instead, a staggered application is laid down.

Before the mandatory application dates, suppliers (manufacturers, importers, downstream users and distributors) are not yet required to classify, label and package their substances and mixtures, according to the revised legislation, but may do so on a voluntary basis. However, by the mandatory application dates, all suppliers must apply the changes on classifying, labelling and packaging of substances and mixtures.

Classification

One of the main aims of CLP is to determine whether a substance or mixture has properties that lead to a hazard classification. In this context, classification is the starting point for hazard communication.

When relevant available information (e.g. eco/toxicological data) on a substance or mixture meets the classification criteria in CLP, the hazards of a substance or mixture are identified by assigning certain hazard classes and categories. The hazard classes in CLP cover physical, health, environmental and additional hazards.

Labelling and packaging

Once a substance or mixture is classified, the identified hazards must be communicated to other actors in the supply chain, including consumers. Hazard labelling allows the hazard classification, with labels and safety data sheets, to be communicated to the user of a substance or mixture. It alerts them to the presence of a hazard and the need to manage the associated risks. It also sets general packaging standards to ensure the safe supply of hazardous substances and mixtures.

Additionally, Harmonised classification and labelling, Alternative chemical names in mixtures, Classification and Labelling Inventory (C&L Inventory) and Poison centres, are processes that are part of CLP.

Understanding CLP 2

Harmonised classification and labelling

The classification and labelling of certain hazardous substances is harmonised to ensure adequate risk management throughout the EU.

The European Commission may request ECHA or the European Food Safety Authority (EFSA) to prepare a harmonised classification and labelling (CLH) proposal for a substance or a group of substances. Also, Member State Competent Authorities (MSCAs) and manufacturers, importers or downstream users may propose a harmonised classification and labelling for a substance or a group of substances. Only MSCAs or the Commission can submit a revision of an existing CLH and/or a CLH when a substance is an active substance in biocidal or plant protection products..

Alternative chemical names in mixtures

Through this process, suppliers can request the use of an alternative chemical name for a substance present in a mixture, to protect the confidential nature of their business, and in particular, their intellectual property rights. Any requests for alternative chemical names approved by ECHA will be valid in all the EU.

Classification and Labelling Inventory (C&L Inventory)

The notification obligation under CLP requires manufacturers and importers to submit classification and labelling information for the hazardous substances they are placing on the market to the C&L Inventory held by ECHA. ECHA publishes certain information submitted to the inventory.

Poison centres

Annex VIII to CLP, implements harmonised information requirements for notifications under Article 45. This information is submitted to the appointed bodies in the MSCAs through the ECHA submission portal and is used for emergency health response by the national Poison Centres.

Annex VIII defines a Unique Formula Identifier (UFI), which is required on the CLP label of a hazardous mixture, creating an unambiguous link between a mixture placed on the EU market and the information made available to the emergency health response. Each UFI will refer to one, and only one, mixture composition.