Digital label under CLP: obligations, company actions and technical implementation (QR code)

MSDS-Europe – Compass to Chemical Safety – Digital label under CLP: obligations, company actions and technical implementation (QR code)

 

In brief: After the CLP amendment, a digital label can be used voluntarily, but it does not exempt you from the mandatory hazard communication that must appear on the physical label.

The key to compliance is a company process that manages, in parallel, classification, labelling, the safety data sheet (SDS) and the digital interface updates—in an auditable way and designed for long-term operation.

 

1) Legal background: what did Regulation (EU) 2024/2865 change in CLP?

Regulation (EU) 2024/2865 amended the CLP Regulation (Regulation (EC) No 1272/2008), among other reasons to ensure the framework keeps pace with online sales and new sales models.

One practical message of the amendment is that the legislator allows multiple tools to address “lack of space” on labels (e.g., a fold-out label and digital labelling), while critical safety information and hazard pictograms must remain on the packaging.

 

2) Deadlines: what applies already, and what moved to 2028?

The amended CLP entered into force on 10 December 2024 and applies transitional periods for several obligations.

A key practical development is that in 2025 a “stop-the-clock” amendment further postponed several application dates to 1 January 2028, especially for online/distance selling rules, advertisements, certain formatting requirements and some relabelling obligations.

What does this mean for companies?

The postponement is not “downtime”—it is an opportunity to build technical and organisational compliance in pilot mode in 2026–2027, so that by 2028 the process runs routinely and reliably.

New CLP rules for webshops: labelling and advertising (from 2028)

3) The mandatory “core” of the physical label: what cannot be replaced by a digital label?

The logic of the digital label is simple: it supplements—it does not “replace”. The physical label remains mandatory even if a QR code is used.

Must remain on the packaging (mandatory):

 

Why is the physical minimum so strict?

  • In an emergency, there may be no time (and not always the possibility) to scan a QR code.
  • Power outages, lack of network coverage/internet, or a discharged device can occur.
  • Regulation cannot rely on universal digital access (risk of a “digital divide”).

 

4) What is worth placing on the digital label?

The typical role of a digital label is to provide supplementary information in a structured, multilingual and quickly updatable way—kept clearly separate from marketing or other content.

In practice, this may include:

  • multilingual content (especially useful for the EU market),
  • opening/downloading the safety data sheet (with language versions),
  • more detailed instructions for use, dosing recommendations,
  • waste management and recycling information,
  • customer support / expert contact information and supplementary emergency guidance.

 

5) Technical compliance with Article 34b: checklist (not just “QR code + website”)

For digital labelling, compliance does not start with printing a QR code—it starts with building a quality-assurable service.

 

5.1. Access and user journey

Information available via the digital label should be:

  • free of charge and without registration,
  • searchable and accessible,
  • available within two clicks,
  • accessible to all EU users under the same principles.

 

5.2. Content separation

Digital label information must be displayed “in one place”, separately from other content (especially important if other corporate content is hosted on the same domain).

 

5.3. Data protection and “tracking-free” operation

The purpose of the digital label is safety information. Therefore, a compliance-grade solution should, in practice, minimise user tracking (especially marketing tracking).

Recommended technical approach: a dedicated “digital label” subdomain or path without marketing pixels and targeted cookies; only minimal, documented logging necessary for operation.

 

5.4. Availability and retention

Information published via the digital label must remain accessible for at least 10 years. This is not only a hosting issue; it is business continuity (domain changes, system upgrades, acquisitions).

 

5.5. Physical durability and placement of the QR code

The QR code is part of the packaging and must withstand the stresses arising from the product’s nature (rubbing, moisture, chemical exposure).

Recommended:

  • appropriate printing technology / lamination,
  • placement where it will not wear off,
  • internal testing (e.g., washability, solvent resistance) as part of production control.

 

6) Company-level actions: a practical compliance roadmap for manufacturers and distributors

The steps below also work if the digital label is introduced gradually.

 

6.1. Portfolio screening and risk ranking

  1. Create an SKU list: which products go to multiple countries, in what pack sizes, and how often classification / composition changes.
  2. Select the “highest value” group for digital labels first (e.g., multilingual distribution, small packaging, high e-commerce share).

 

6.2. Put the physical label in order (this is the foundation)

A digital label is only safe if physical compliance is stable:

  • classification → correctness of label elements,
  • typography/readability,
  • multilingual logic and managing country-specific differences.

 

6.3. Digital label data content and version control

Create an internal data model (fields, languages, mandatory/recommended elements) and add version control:

  • “Last updated” date,
  • internal version number,
  • approver role/person (QA/Regulatory).

 

6.4. IT implementation (minimum defensible architecture)

Recommended pattern:

  • QR code → stable URL (SKU or internal identifier),
  • URL leads to a dedicated digital label landing page,
  • language switch in 1 click; content within 2 clicks.

 

Design for retention:

  • redirect rules for domain changes,
  • regular backups,
  • assign an operations owner (10-year horizon).

 

6.5. Change management: update label and SDS together

Under the amended CLP, the deadline for a label update depends on the type of change: it can be as short as 6 months (e.g., a new hazard class or a more severe classification, or new supplemental labelling requirements), while in other cases it can be 18 months.

Therefore, it is best practice to manage in one integrated workflow:

  • classification change,
  • label draft update,
  • safety data sheet update,
  • digital label content update.

If your portfolio includes mixtures, pay special attention to the new hazard class requirements applicable to mixtures from 1 May 2026: this typically triggers coordinated review of classification, labelling and the SDS.

CLP 2026: New hazard classes for mixtures – what to do

6.6. Check UFI/PCN relevance (critical point for mixtures)

For mixtures, labelling often intersects with poison centre obligations (UFI and PCN). For safe operation, use a single “dossier logic”: information submitted for PCN should be consistent with the label and the SDS.

 

6.7. E-commerce and advertising: prepare now for 2028

The CLP revision strengthens online presentation requirements (visibility of hazard information on the web), and multiple related obligations have shifted to 2028. Use 2026–2027 to clean data, build interfaces and run pilots.

 

7) “Minimum viable” digital label page: which fields should it include?

A legally and operationally defensible digital label page typically includes:

  • Product name / identifier (internal product code)
  • Supplier details (contact)
  • Language selector
  • Separated labelling block: hazard pictograms, signal word, H statement(s), P statement(s)
  • Supplementary information (e.g., use, storage, waste management / waste disposal)
  • Safety data sheet download (by language)
  • Version and “last updated” date
  • “Alternative access” information (how to obtain the content free of charge if the digital label is temporarily unavailable)

 

8) Outlook: Digital Product Passport (DPP) – why it is worth considering

A digital label is not the same as a Digital Product Passport, but the underlying capabilities partly overlap (identifiers, data quality, version control, long-term availability).

The ESPR introduces the Digital Product Passport (DPP) concept to support electronic availability of sustainability and compliance information.

 

FAQ

Is it mandatory to introduce a digital label?
No. It is a voluntary option; the physical label remains mandatory.

Can hazard communication be provided only via a QR code?
No. The critical elements must be on the packaging (hazard pictogram, signal word, H and P statements).

What exactly does the “within two clicks” principle mean?
After scanning the QR code, the information must be accessible free of charge in no more than two user steps (e.g., language selection + opening the content).

How long must the digital label page remain available?
It must remain accessible for at least 10 years.

Can marketing analytics be used on a digital label page?
From a compliance perspective it is risky. The purpose of the digital label is safety information; minimising tracking aligns with the logic of the requirements.

What happens if the digital label is not available at the time of purchase?
The information must also be provided by alternative means, free of charge (e.g., customer support channel, downloadable documents).

 

Summary

The 3 pillars of compliance:

  1. Physical label compliance: mandatory hazard communication remains on the packaging.
  2. Technical compliance of the digital label: 2 clicks, 10 years, accessibility, separated content, data-protection discipline.
  3. Change management: classification → label → safety data sheet → digital interface must be updated together within CLP deadlines.

 

As a next step, most companies achieve fast progress by first checking and, if needed, updating the legal compliance of the label draft, and in parallel building the “minimum” specification of the digital label landing page—well before 2028.

 

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