Overview#
CLP is the EU's rulebook for chemical hazard labelling. It decides how dangerous a substance or mixture is and how that danger must be communicated on labels and packaging. It is the EU's implementation of the UN's GHS, which is why an EU label looks like one from Japan or Australia, and it is the source of the red-bordered pictograms and the H and P statements that appear on any hazardous chemical you buy.
Who has to do what#
Article 4 sets the obligations, and it assigns them by role in the supply chain.
Where a substance has an entry in Part 3 of Annex VI, Article 4(3) says that entry governs for the hazard classes it covers, and the supplier does not self-classify for those classes. Self-classification still has to be done for any hazard class the entry does not cover, and for any form or physical state it does not mention.
The hazard classes#
Annex I sorts hazards into four parts. A substance can sit in several classes at once, and each class has categories that grade the severity.
The three CMR classes in Part 3, mutagenicity, carcinogenicity and reproductive toxicity, are the ones a product compliance team meets most often, because a category 1A or 1B classification in any of them is the usual road to a substance becoming an SVHC under REACH.
Delegated Regulation (EU) 2023/707 added four groups of classes that did not exist in the UN GHS: endocrine disruption for human health and for the environment, PBT and vPvB, and the mobility-based pair PMT and vPvM. Substances had to be classified against them from 1 May 2025, mixtures from 1 May 2026, each with a grace period for stock already on the market (to 1 November 2026 and 1 May 2028 respectively). They carry no pictogram; the hazard is communicated through new EUH statements.
What a label must carry#
Article 17(1) lists the elements. A hazardous substance or mixture in packaging must be labelled with:
The label must be in the official language or languages of the member state where the product is placed on the market, unless that state provides otherwise, and a supplier may add more languages so long as every language carries the same details (Article 17(2)). Articles 31 and 32 add the physical rules: firmly affixed, readable horizontally when the package is set down normally, the pictogram standing out clearly, and pictograms, signal word, H statements and P statements located together. The dimensions of the label and the pictograms scale with the package size under Annex I section 1.2.1, and from 1 January 2027 that table also prescribes minimum font sizes.
Which pictograms appear, and why a label often shows fewer than the classification would suggest, is explained on the GHS pictograms page.
Annex VI: the harmonised list#
Most classification is self-classification by the supplier. For the most serious hazards the EU decides centrally, and the decision is written into Part 3 of Annex VI as a harmonised classification that every supplier must apply. Article 36(1) says a substance meeting the criteria for the following is normally harmonised:
- respiratory sensitisation, category 1, 1A or 1B
- germ cell mutagenicity, carcinogenicity or reproductive toxicity, category 1A, 1B or 2
- endocrine disruption for human health or for the environment, category 1 or 2
- PBT, vPvB, PMT or vPvM
Active substances in plant protection products and biocides are always harmonised, and any other hazard class can be harmonised case by case where an EU-level decision is justified. Under Article 37 a member state authority proposes an entry, or a manufacturer, importer or downstream user does, and since the 2024 revision the Commission may ask ECHA or EFSA to prepare one; ECHA's Committee for Risk Assessment gives an opinion; the Commission adopts the entry by delegated act. That is how Annex VI grows by an "ATP", an adaptation to technical progress, every year or so.
The 2024 revision#
Regulation (EU) 2024/2865 is the first broad revision of CLP since 2008. It was published on 20 November 2024, entered into force on 10 December 2024, and staggers its obligations over two dates.
Three of the changes matter most to anyone who sells chemicals:
- Digital labelling is optional, and it is an addition, not a substitute. Article 34a keeps the physical label mandatory. A data carrier such as a QR code may link to a digital version, and only the supplemental elements listed in Annex I section 1.6 may move to digital only; those must then be available on request, free of charge, without any app, registration or password, and for at least ten years.
- Online offers must show the hazard. Article 48a requires a distance sales offer to indicate the Article 17 label elements clearly and visibly, so a web shop listing has to show the pictograms, signal word and statements, not a photograph of the can.
- Labels get a minimum font size. From 1 January 2027 Annex I Table 1.3 sets an x-height of 1,2 mm for packages up to half a litre, rising to 2,0 mm above 50 litres, in a single sans-serif font, black on white, with line spacing of at least 120% of the font size.
CLP label and safety data sheet are two documents#
On the package. Required by CLP Article 17 for every hazardous substance or mixture, whoever buys it. Carries the classification result in compressed form: pictograms, signal word, H and P statements.
Sent to the professional customer. Required by REACH Article 31 and formatted to REACH Annex II. Section 2 states the CLP classification and label elements in full; the other fifteen sections carry what the label cannot.
A "CLP-compliant safety data sheet" is therefore a REACH document whose section 2 has been filled in from CLP correctly. The safety data sheet page covers the sixteen sections.
Where CLP stops#
Article 1 takes several things out of scope: radioactive substances, goods under customs supervision in transit, non-isolated intermediates, and substances for research and development that are not placed on the market. It also leaves alone, in their finished state for the end user, medicinal and veterinary products, cosmetics, certain medical devices, and food and feed, which have their own labelling regimes. Waste is not a substance, mixture or article for CLP purposes. Articles are outside the labelling duty altogether, except the explosive articles of Annex I section 2.1.
How it relates to other topics#
Decides how hazardous a substance is and how to label it.
Decide what to do about hazardous substances, whether to register, restrict, authorise or ban, often using CLP classifications as the trigger.