CLP Regulation: Classification, Labelling and Packaging
SHAPYPRO provides technical and regulatory support for applying the CLP Regulation to chemical substances and mixtures placed on the European Union market.
The service includes classification review, label preparation and control, packaging requirements, UFI and poison centre notifications, consistency with Safety Data Sheets and adaptation to the changes introduced by Regulation (EU) 2024/2865.
- CLP classification
- Labelling and packaging
- UFI and PCN
- SDS consistency
CLP Regulation Compliance Services
Applying CLP means converting technical information on a substance or mixture into a justified classification and clear, legally compliant hazard communication.
SHAPYPRO adapts its support to the product, available documentation, the company’s role in the supply chain and the countries where the product is supplied.
Classification of Substances and Mixtures
Assessment of physical, health and environmental hazards using available data, harmonised classifications and applicable calculation or bridging rules.
Review of Existing Classifications
Verification of internal or supplier classifications to identify outdated data, incorrect thresholds or hazard categories that have not been considered.
Label Preparation and Review
Verification of identifiers, pictograms, signal word, H statements, P statements, supplemental information, UFI and supplier details.
Packaging Requirements
Assessment of child-resistant fastenings, tactile warnings, packaging resistance, appearance and other applicable duties.
UFI and Poison Centre Notifications
Support in determining harmonised notification duties, preparing the required information and maintaining consistency between composition, UFI, label and documentation.
Safety Data Sheet Consistency
Cross-checking of CLP classification, SDS Section 2, composition, properties, transport information and risk-management measures.
Adaptation to Regulatory Changes
Assessment of new ATPs, harmonised classifications, new hazard classes and amendments to the CLP Regulation.
Online Sales and Multilingual Labelling
Review of information required in distance-sale offers and language adaptation for the Member States where the product is placed on the market.
What CLP Regulates and Who Must Comply
Regulation (EC) No 1272/2008 governs the classification, labelling and packaging of chemical substances and mixtures in the European Union. It implements the principles of the UN Globally Harmonised System and defines how hazards are identified and communicated.
Duties may affect manufacturers, importers, downstream users, distributors and other suppliers. Responsibilities depend on whether the company formulates, imports, modifies, repackages, relabels or merely distributes the product.
Classify before Placing on the Market
The substance or mixture must be assessed before supply using all adequate and available information.
Label and Package Correctly
Products classified as hazardous must communicate hazards through a compliant label and suitable packaging.
Keep Classification Updated
New information, formulation changes or regulatory amendments may require a review of classification and labelling.
Notify Where Required
Certain substances require notification to the Classification and Labelling Inventory, while certain hazardous mixtures require harmonised poison centre notification.
Retain Supporting Evidence
The company should be able to justify the data, calculations, decisions and sources used to classify and label the product.
Classification of Substances and Mixtures
Classification determines which hazards the product presents and triggers labelling, packaging, communication and, in some cases, notification duties.
The process starts with correct identification of the product and its composition. Harmonised classifications, experimental data, supplier information, regulatory dossiers and the applicable classification criteria are then reviewed.
1
Harmonised Classification
Where an applicable Annex VI entry exists, the harmonised classification must be used for the hazard classes and forms covered by that entry.
2
Self-Classification
Hazards not covered by harmonised classification must be assessed by the manufacturer, importer or downstream user according to CLP criteria.
3
Mixture Classification
Depending on the hazard class, classification may use data on the mixture, bridging principles or calculation rules based on its components.
4
Specific Limits and Factors
Specific concentration limits, M-factors, acute toxicity estimates, cut-off values and other rules that affect the result must be reviewed.
5
Physical Form and Composition
Physical state, particle size, concentration, impurities and compositional variability may influence classification.
6
Weight-of-Evidence Approach
Where data from different sources are available, the conclusion should consider quality, relevance and consistency, documenting the reasoning followed.
Hazard Classes and New CLP Categories
CLP organises hazards into physical, health, environmental and additional hazard classes. Each class contains criteria and categories that determine severity and the applicable communication elements.
Commission Delegated Regulation (EU) 2023/707 introduced new hazard classes. Different transition periods apply to substances and mixtures, so each product should be reviewed according to its specific date and regulatory situation.
Physical Hazards
Explosives, flammable gases, aerosols, flammable liquids and solids, oxidisers, self-reactive substances, pyrophorics, corrosive-to-metal hazards and other physicochemical classes.
Health Hazards
Acute toxicity, corrosion and irritation, sensitisation, mutagenicity, carcinogenicity, reproductive toxicity, target-organ toxicity and aspiration hazard.
Environmental Hazards
Acute and chronic aquatic hazards and hazard to the ozone layer.
Endocrine Disruption
New categories for endocrine-disrupting properties relevant to human health and the environment.
PBT and vPvB
Classes for persistent, bioaccumulative and toxic substances, and very persistent and very bioaccumulative substances.
PMT and vPvM
Classes for persistent, mobile and toxic substances, and very persistent and very mobile substances.
The new hazard classes should not be added mechanically to every label. The criteria, available data and applicable transition periods for substances and mixtures must first be assessed.
Labelling and Hazard Communication
The label must make the product, its hazards and essential prevention measures immediately identifiable and legible. Its content follows from classification but also depends on label format, package size, language and sector-specific legislation.
Precautionary statements should be selected to avoid unnecessary repetition while retaining the messages needed for safe use. The label must be consistent with the SDS and the product actually placed on the market.
Product Identifier
Name of the substance or identification of the mixture consistent with the Safety Data Sheet and declared composition.
Supplier Details
Name, address and telephone number of the EU-established supplier responsible for placing the product on the market.
Hazard Pictograms
Red-framed symbols selected according to the applicable hazard classes and categories, taking precedence rules into account.
Signal Word
Use of “Danger” or “Warning” according to the severity of the classifications.
H and EUH Statements
Statements describing hazards and supplemental information required for certain substances or mixtures.
P Statements
Prevention, response, storage and disposal measures selected for the product and its uses.
Nominal Quantity and UFI
Additional elements applicable to certain products supplied to the general public or mixtures subject to Annex VIII.
Language and Readability
Information should be presented in the languages required by the Member State and with appropriate size, contrast and layout.
Packaging, Child-Resistant Fastenings and Tactile Warnings
CLP regulates more than the label text. Packaging must prevent leakage, withstand intended handling and not react with the contents or use shapes and designs that attract children or mislead consumers.
Depending on classification, concentration and packaging type, additional requirements may apply to reduce accidental exposure.
Integrity and Compatibility
Packaging and closures should withstand the contents and normal conditions of storage, transport and use.
Child-Resistant Fastenings
Certain substances and mixtures supplied to the general public require fastenings that meet the applicable specifications.
Tactile Warnings
Some classifications require a tactile warning of danger to assist identification by visually impaired users.
Small or Special-Shaped Packaging
Specific provisions, fold-out labels or limited derogations may apply where space is insufficient.
Inner and Outer Packaging
The placement of CLP elements should be reviewed for single, combination and transport packaging.
Refill Stations
The revised CLP introduces specific conditions and restrictions for supplying hazardous products through refill systems.
UFI and Poison Centre Notifications
Mixtures classified for physical or health hazards may be subject to harmonised obligations under Annex VIII to CLP. The information is used to support appropriate health-emergency response following accidental exposure.
Since 1 January 2025, notifications that remain required must comply with the harmonised format. The UFI links the marketed mixture to its notified composition and must be carefully managed.
Determining the Duty
Review of classification, uses, markets, responsible importer or formulator and possible exemptions.
UFI Generation and Management
Creation of the identifier and application of the principle linking one UFI to one notified composition.
PCN Submission Information
Product identity, composition, classification, uses, packaging, colours, categories and submitter details.
Placement of the UFI
It normally appears on the label or inner packaging, with specific rules for industrial-site or unpackaged products.
Updates
Changes to composition, classification, identifiers, uses or commercial information may require an update of the submission.
Distributors and the Supply Chain
The CLP revision clarifies additional responsibilities where the notified information does not cover the country or trade name used by a distributor.
CLP Revision: Regulation (EU) 2024/2865
Regulation (EU) 2024/2865 amends CLP to address new ways of selling chemicals, improve label readability and strengthen compliance in online sales.
It entered into force on 10 December 2024 and provides for phased application of different provisions from 1 July 2026 and 1 January 2027, with transitional rules for products already placed on the market.
EU-Established Supplier
Products placed on the market, including through distance sales, must have an EU-established supplier responsible for CLP compliance.
Label Format and Readability
Requirements on font size, spacing, contrast, layout and the use of fold-out labels are strengthened.
Digital Labelling
The physical label may be supplemented by a digital data carrier, and certain non-safety-critical elements may be supplied only digitally.
Advertising of Hazardous Products
The new rules require relevant hazard information and prohibit claims such as “non-toxic”, “harmless” or “eco-friendly” where inconsistent with classification.
Distance-Sale Offers
Online offers must clearly display label elements before the purchaser concludes the transaction.
Refill Stations
Information requirements, safety measures and prohibitions are introduced for certain hazard classes.
Classification and Updates
Deadlines and duties for updating labels when new information becomes available or classification changes are clarified.
Poison Centre Notifications
Responsibilities of importers, downstream users and distributors and the events requiring updates are clarified.
Application is phased. Before changing a label or sales process, the applicable provision, date and any transitional period for the product should be checked.
Relationship with SDS, REACH, Biocides and Cosmetics
CLP forms part of a wider regulatory system. The same classification may affect the Safety Data Sheet, REACH restrictions, a biocidal authorisation or the assessment of cosmetic raw materials.
CLP and Safety Data Sheets
Classification, label elements and other hazard information should match SDS Section 2 and the technical data in the document.
CLP and REACH
REACH governs registration, evaluation, authorisation and restriction, while CLP determines how hazards are classified and communicated.
CLP and Biocidal Products
Classification may affect authorisation, the SPC, labelling, advertising, the SDS and risk-management measures.
CLP and Cosmetics
Finished cosmetic products intended for the final user are outside CLP labelling, while raw materials, bulk products and intermediate mixtures may remain subject to the Regulation.
CLP and Transport
Transport classification follows ADR, RID, IMDG or ICAO/IATA rules and should be reviewed consistently, although it is not identical to CLP classification.
Common Errors in CLP Application
Failures often result from copying raw-material information without evaluation, retaining old labels or treating classification as a task separate from the rest of the documentation.
Outdated Classification
New ATPs, harmonised entries, formulation changes or new hazard classes have not been considered.
Incorrect Calculations
Generic limits are applied where specific concentration limits, M-factors or acute toxicity estimates exist.
Incomplete Label
Identifiers, EUH statements, UFI, nominal quantity, supplier details or relevant precautionary statements are missing.
Inconsistent SDS and Label
Classification, hazardous components or safety measures differ between documents.
Incorrect Language or Format
The label does not meet the language, font-size or readability requirements of the target market.
PCN Not Updated
Composition or trade names have changed without reviewing the UFI and notification.
Insufficient Online-Sale Information
The offer allows purchase without displaying the necessary hazard elements beforehand.
Claims Inconsistent with Classification
Advertising uses statements that minimise or contradict the hazards of the product.
Technical Support for CLP Classification and Labelling
Each substance or mixture requires an individual assessment. SHAPYPRO adapts the service to composition, uses, sales format, target markets and available documentation.
The objective is to obtain a defensible classification, a clear label and consistent documentation that support product marketing and regulatory maintenance.
