CLP

The CLP Regulation ensures uniform hazard communication across the EU and is closely linked with REACH. Companies – manufacturers, importers, and downstream users – must classify and correctly label all hazardous substances and mixtures before placing them on the market, regardless of the supplied volume.

Classification and Labelling

Each substance is classified into hazard classes and categories according to defined criteria. Classification is either performed independently by the company or based on harmonised classifications (CLH), which are legally binding across the EU for certain particularly hazardous substances. The resulting labelling must be communicated on packaging using standardised pictograms, signal words (Danger/Warning), as well as hazard statements (H-statements) and precautionary statements (P-statements).

Notification Obligation and the C&L Inventory

Manufacturers and importers are obliged to submit their classification and labelling information to the ECHA Classification and Labelling Inventory (C&L Inventory). This notification obligation ensures transparency and enables verification of whether different companies classify the same substance differently.

Integration with REACH

CLP forms the basis for numerous REACH processes: the classification of a substance determines, among other things, whether extended safety data sheets are required, whether the substance is a candidate for SVHC (Substance of Very High Concern) status, or which risk management measures apply. The information obligation under Article 33 of REACH for articles containing substances of very high concern is also based on CLP criteria.

Operational Implementation in the Supply Chain

In practice, companies must integrate CLP requirements into their QM, ERP, and PLM systems. This includes maintaining substance data, automatically generating compliant labels, creating and updating safety data sheets, and ensuring consistent communication along the supply chain. Particularly for mixtures, the classification logic must be correctly applied to the constituent substances.

Specific Provisions

The CLP Regulation contains specific procedures for harmonised classifications (CLH process), alternative chemical names to protect trade secrets, and, since 2017, harmonised requirements for notifications to poison centres (Annex VIII) including the Unique Formula Identifier (UFI) for mixtures.