The CLP regulation - a global overview

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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 27 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 in the Community and manufacturing a substance in the Community";
  • importer: "any natural or legal person established in the Community and responsible for imports";
  • 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.

Prerequisites

It is important to determine the company status in accordance with the CLP regulation ("manufacturer", "importer" or "downstream user") as the status determines the obligations that the business must fulfil.

How to proceed

CLP regulation

The CLP regulation has applied to substances since 2010, and to mixtures as of June 2015. It has been fully applicable since June 2017 following the end of the transitional periods initially provided for in the Regulation, which allowed companies to apply it gradually.

It has three main sections:

  • classification;
  • labelling;
  • packaging.

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. 

Classification

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 4 main stages in the classification of a substance or mixture:

  1. collection of available information;
  2. assessment of the adequacy and reliability of the information;
  3. analysis of the information in relation to the classification criteria;
  4. 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:
    • explosives;
    • 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;
    • carcinogenicity;
    • reproductive toxicity;
    • specific target organ toxicity (STOT) - single exposure;
    • specific target organ toxicity (STOT) - repeated exposure;
    • aspiration toxicity 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.

In compliance with the CLP regulation, the hazard pictograms are represented by white diamonds framed in red with a black symbol inside.

 

 

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 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).

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.

Who to contact

2 of 9 bodies shown

Related procedures and links

Procedures

The REACH Regulation - a global overview

Links

Further information

Legal references

  • Regulation (EC) No 1272/2008 of the European Parliament and of the Council of 16 December 2008

    on classification, labelling and packaging of substances and mixtures

  • Loi du 16 décembre 2011

    concernant l'enregistrement, l'évaluation et l'autorisation des substances chimiques ainsi que la classification, l'étiquetage et l'emballage des substances et mélanges chimiques

  • Arrêté grand-ducal du 7 mars 2019

    portant publication de l'Accord européen relatif au transport international des marchandises dangereuses par route (ADR), signé à Genève en date du 30 septembre 1957 et approuvé par la loi du 23 avril 1970, du protocole de signature et des annexes A et B, y compris les amendements en vigueur au 1er janvier 2019

  • Arrêté grand-ducal du 7 mars 2019

    portant publication de l'Accord européen relatif au transport international des marchandises dangereuses par voies de navigation intérieures (ADN), fait à Genève, le 26 mai 2000, y compris le Règlement annexé, en vigueur le 1er janvier 2019

  • Arrêté grand-ducal du 7 mars 2019

    portant publication du Règlement concernant le transport international ferroviaire des marchandises dangereuses (RID), Appendice C à la Convention relative aux transports internationaux ferroviaires (COTIF), signée à Vilnius, le 3 juin 1999 et approuvée par la loi du 15 juin 2006, y compris les amendements en vigueur au 1er janvier 2019

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