The CLP label, labelling in practice

Safety data sheet knowledge base – CLP labelling in practice

 

Products subject to chemical safety requirements must be labelled in accordance with Regulation (EC) No 1272/2008 (CLP).

 

Labelling obligation

  • If the substance or mixture is classified as hazardous in accordance with the CLP Regulation
  • If it is an explosive article
  • If it is a non-hazardous mixture containing one or more substances classified as hazardous above the concentrations referred to in Part 2 of Annex II to the CLP Regulation

Derogations for packages ≤ 125 ml (Section 1.5.2 of Annex I to Regulation (EC) No 1272/2008 (CLP))

 

Information sources for preparing a CLP label

As an importer

The label should be prepared in accordance with Title III of Regulation (EC) No 1272/2008 (CLP).

As a distributor

When preparing a label (e.g. for relabelling in the language of the target country), the label elements should be aligned with Section 2.2 of the safety data sheet and the CLP requirements.

As a reseller

Typically, no action is needed, except where the label is damaged or changes are made that require relabelling.

 

General labelling aspects

  • “Hazard communication in the form of labelling” principle
  • Language of the label
  • Supplemental information on the label
  • Readability and visibility rules
  • Organisation rules

 

Elements of the label for hazardous products

  • The name, address and telephone number of the supplier(s)
  • Nominal quantity (for packages made available to the general public, where applicable)
  • Product identifier(s)

Where applicable:

* For consumer products, precautionary statements may also include instructions for disposal of the substance or mixture and disposal of the packaging as waste, where applicable.

  • Supplemental information section (mandatory and additional elements, where applicable)

 

Mandatory supplemental information on the label (where applicable)

  • EUH statements (supplemental hazard information) as set out in the relevant parts of the CLP Regulation
  • Additional hazard statement elements required for certain substances/mixtures under Annex I (where applicable)
  • Information on special responses (where required)
  • EUH401 statement for plant protection products (where applicable)
  • Label elements resulting from requirements specified in other legislation (e.g. detergents: surfactants and fragrances; aerosols: flammability labelling; VOC content under Directive 2004/42/EC; and relevant online advertising/labelling requirements – CLP Rules for Webshops: Labelling and Advertising)
  • Mixtures with specific EUH statements (examples):
  • Mixtures containing lead
  • Mixtures containing cyanoacrylates
  • Cements and cement mixtures
  • Mixtures containing isocyanates
  • Mixtures containing epoxy constituents with an average molecular weight ≤ 700
  • Mixtures containing active chlorine
  • Mixtures containing cadmium (alloys) intended for brazing or soldering
  • Mixtures not classified as sensitising but containing at least one sensitising substance
  • Liquid mixtures containing halogenated hydrocarbons
  • Mixtures not intended for the general public containing certain substances above specified minimum concentrations
  • Aerosols

 

Minimum dimensions of labels and pictograms

According to Commission Regulation (EU) No 286/2011:

CapacityMinimum label dimensions (mm)Minimum dimensions of each hazard pictogram (mm)
< 3 litres52 × 7410 × 10 (min.), 16 × 16 (recommended)
3 – 50 litres74 × 10523 × 23
50 – 500 litres105 × 14832 × 32
> 500 litres148 × 21046 × 46

 

Special labelling instructions

  • Transportable gas cylinders (Section 1.3.1 of Annex I to the CLP Regulation)
  • Gas containers intended for propane, butane or liquefied petroleum gas (LPG) (Section 1.3.2 of Annex I to the CLP Regulation)
  • Aerosols and containers fitted with a sealed spray attachment containing substances or mixtures classified as presenting an aspiration hazard (Section 1.3.3 of Annex I to the CLP Regulation)
  • Metals in massive form; alloys; mixtures containing polymers; mixtures containing elastomers (Section 1.3.4 of Annex I to the CLP Regulation)
  • Explosives placed on the market with a view to obtaining an explosive or pyrotechnic effect (Section 1.3.5 of Annex I to the CLP Regulation)

 

Offered services

 

Recommended article(s)

 

Quick questions and answers

How does Regulation (EU) 2020/878 affect the content of safety data sheets?

Commission Regulation (EU) 2020/878 amended Annex II to the REACH Regulation, introducing updated structure and content requirements. From 1 January 2023, only SDSs complying with Regulation (EU) 2020/878 may be placed on the market.

When is a CLP label mandatory on a product?

A label is required when the substance or mixture is classified as hazardous under CLP, when it is an explosive article, or when a non-hazardous mixture contains a hazardous ingredient above the applicable threshold triggering labelling obligations.

What is the minimum label and pictogram size for 3–50 L packages?

For this volume range, the label must be at least 74 × 105 mm and each hazard pictogram must be at least 23 × 23 mm.

Where and in what format must the UFI be displayed?

The UFI must be shown on the label in the format “UFI: XXXX-XXXX-XXXX-XXXX”, clearly visible and indelible. In specific cases (e.g. very small packaging or certain industrial-use mixtures), alternative placement options may apply in accordance with Annex VIII requirements.

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