The CLP regulation (Classification, Labelling and Packaging) concerns the classification, labelling and packaging of chemical substances and mixtures.
It is applicable in the European Economic Area (EEA), i.e. the 28 Member States of the European Union (EU), plus Iceland, Liechtenstein and Norway (also referred to as "European Union" or "Community" in the context of the CLP regulation).
The purpose of the CLP regulation is to ensure that clear information is provided to workers and consumers in the European Union on the hazards associated with chemicals, by means of the classification and labelling of chemical substances and mixtures.
Before placing chemical products on the market, the industry must determine the potential risks of these substances and mixtures to human health and the environment, and classify them in accordance with the hazards identified. Hazardous chemicals must also be labelled according to a standardised system, so that workers and consumers are aware of their effects before using them.
The European Chemicals Agency (ECHA) is responsible for implementing the CLP regulation and for providing a framework for the related procedures, in order to enable uniform implementation within the EU.
Who is concerned
Under the CLP regulation, all suppliers in a supply chain must work together to ensure compliance with classification, labelling and packaging requirements.
In case they do not, the specific obligations under the CLP regulation depend on the role in the supply chain.
The main roles, as defined in the CLP regulation, are:
- manufacturer: "any natural or legal person established within the Community who manufactures a substance within the Community"
- importer: "any natural or legal person established within the Community who is responsible for import"
- downstream user: "any natural or legal person established within the Community, other than the manufacturer or the importer, who uses a substance, either on its own or in a mixture, in the course of his industrial or professional activities".
This applies to all actors in the chemicals industry, as well as to users of chemicals, for example:
- the automotive industry;
- the plastics industry;
- the textile industry;
- the cleaning industry;
- the paint industry;
- the construction industry, etc.
It is important to determine the company status in accordance with the REACH regulation ("manufacturer", "importer" or "downstream user"), as the status determines the obligations that the business must fulfil.
How to proceed
The CLP regulation has applied to substances since 2010, and it will apply to mixtures from June 2015.
It has three main sections:
The CLP also requires manufacturers to notify the European Chemicals Agency (ECHA) of substances classified as hazardous so that they may be included in the Classification and Labelling Inventory (C&L Inventory).
The CLP is based on the Globally Harmonized System (GHS), a set of recommendations drafted by the United Nations (UN). It is mainly concerned with harmonising:
- classification criteria for chemical substances and mixtures (with regard to the physical hazards for health and the environment);
- rules relating to labelling and packaging of hazardous substances and mixtures.
Moreover, the CLP regulation is closely related to:
- the REACH regulation, particularly in terms of the "Safety Data Sheets";
- a number of downstream European regulations (e.g. on biocides and phytopharmaceuticals, Seveso, etc.).
The classification imposes a number of obligations, such as the quantity of hazardous material that may be stored at a site (Seveso III), disposal methods for hazardous waste, and safety in the workplace and protective clothing for employees.
Chemical classifications must reflect the type and severity of the intrinsic risks of a substance or mixture.
This must not be confused with risk assessment. Risk assessments concern the risk posed by the actual exposure of humans or the environment to the substance or mixture presenting this risk.
There are four main stages in the classification of a substance or mixture:
- collection of available information;
- assessment of the adequacy and reliability of the information;
- analysis of the information in relation to the classification criteria;
- decision on the classification.
All substances and mixtures that meet the criteria of one or more of the CLP hazard categories listed below are considered to be hazardous:
- physical hazards:
- flammable gases;
- flammable aerosols;
- oxidising gases;
- gases under pressure;
- flammable liquids;
- flammable solids;
- self-reactive substances and mixtures;
- pyrophoric liquids;
- pyrophoric solids;
- self-heating substances and mixtures;
- substances and mixtures which, in contact with water, emit flammable gases;
- oxidising liquids;
- oxidising solids;
- organic peroxides;
- substances and mixtures corrosive to metals;
- health hazards:
- acute toxicity;
- skin corrosion/irritation;
- eye damage/irritation;
- respiratory/skin sensitisation;
- germ cell mutagenicity;
- reproductive toxicity;
- specific target organ toxicity (STOT) - single exposure;
- specific target organ toxicity (STOT) - repeated exposure;
- aspiration hazard;
- environmental hazards:
- hazardous to the aquatic environment;
- hazardous to the ozone layer.
Labelling and packaging
In accordance with the CLP regulation, suppliers must label a substance or mixture contained within packaging before placing it on the market, where:
- the substance is classified as hazardous;
- the mixture contains one or more substances classified as hazardous above a certain concentration specified in the CLP regulation.
Suppliers can find this information in the safety data sheet (SDS) for the substance concerned.
The label must include the following information:
- the name, address and telephone number of the supplier;
- the nominal quantity of the substance or mixture in the package where this is being made available to the general public (unless this quantity is specified elsewhere on the packaging);
- the product identifiers;
- where applicable, the hazard pictograms, signal words, hazard statements, precautionary statements and supplementary information required by other legislation.
The old-style orange hazard pictograms have now been replaced by white diamonds with a red border.
The CLP regulation covers substances and mixtures in general. For certain chemicals, for example phytopharmaceuticals, detergents and perfumes, further information may be required by specific legislation applicable to a particular product, in addition to the labelling information stipulated by the CLP regulation.
Distributors must not adopt their own classification for labelling purposes; they are required to use the classification for the substance or mixture provided by their supplier.
Classification and Labelling Inventory
The Classification and Labelling Inventory (C&L Inventory) is a database that is updated regularly and contains:
- classification and labelling information on notified and registered substances received from manufacturers and importers;
- a list of harmonised classifications.
The CLP requires manufacturers to notify the European Chemicals Agency(ECHA) of substances classified as hazardous so that they may be included in the Classification and Labelling Inventory (C&L Inventory).
Who to contact
Unit for Permits and Subsidies / Operating Permits Department1, avenue du Rock'n'Roll
Phone : (+352) 40 56 56 - 108.00 - 12.00 and 13.00 - 17.00
Transport and Trade of Waste1, avenue du Rock'n'Roll
Phone : (+352) 40 56 56 310Fax : (+352) 49 62 5608.30 - 11.30 and 14.00 - 17.00
Authorisations and Environmental Management Department1, avenue du Rock'n'Roll
L - 4361 Esch-sur.Alzette
Phone : (+352) 40 56 56 600Fax : (+352) 40 56 56 696
EMAS / European Ecolabel Service1, avenue du Rock'n'Roll
Grand-duché de Luxembourg
Phone : (+352) 40 56 56 - 519