What is the CLP Regulation?
The CLP Regulation (EC) No. 1272/2008 on classification, labelling and packaging of substances and mixtures is the adaptation at a European Union level of the Globally Harmonized System (GHS).
It originally incorporated Revision 2 of the Globally Harmonized System (GHS) and is constantly updated based on the GHS revisions published every two years. The CLP Regulation incorporates the GHS modifications through the so-called ATPs (Adaptations to Technical Progress).
As it is a Regulation, it must be applied in all Member States of the European Union without exception and without modifications.
Since when has it been applied and where?
The CLP Regulation amended several Directives and Regulations and since 1 June 2015 has been the only legislation in force in the EU regarding the classification and labelling of substances and mixtures.
It isbinding on the Member States, applicable to all industrial sectors and closely related to Regulation (EC) No. 1907/2006 (REACH), but they regulate different aspects.
It requires manufacturers, importers and downstream users of substances and mixtures to classify, label and package chemical products in accordance with the CLP before placing them on the market.
What are the aims of the CLP Regulation?
Its purpose is to guarantee a high degree of protection for health and the environment, as well as the free movement of substances, mixtures and articles.
One of the main aims of the CLP Regulation is to determine whether a substance or mixture should be classified as hazardous, which is the starting point for communicating the hazard through labelling and safety data sheets (SDS) in accordance with Regulation (EU) No. 2020/878.
But it has other aims:
- To regulate the packaging of chemicals classified as hazardous.
- To establish a harmonised classification of substances for the entire European Union.
- To create a classification and labelling inventory which includes all the possible classifications of a substance.
- To set the criteria for poison centre notification (PCN).
- To generate the unique formula identifier (UFI).
Which hazards does the CLP Regulation include?
-
Like the Globally Harmonized System (GHS) it refers to three types of hazards for classification and labelling purposes.
- Physical Hazards.
- Health Hazards.
- Environmental Hazards.
The different types of hazards are in turn segmented into hazard classes and categories.
How are hazards communicated?
Hazards must be communicated to all actors in the supply chain: consumers, professional users and industrial users.
Two elements of hazard communication are used for this:
- •The label.
- •The safety data sheet (SDS).
However, the CLP Regulation does not legislate on the content of the safety data sheet as this document is regulated by REACH and Regulation (EU) No 2020/878.
What should the labelling include?
The label will be written in the official language(s) of the Member State(s) where the substance or mixture is placed on the market.
The CLP Regulation sets detailed criteria for labelling elements:
- •Pictograms.
- •Signal words.
- •Hazard statements (H-statements).
- •Precautionary statements (P-statements).
- •Additional information (EUH-statements).
- •Product and supplier identification.
Likewise, the label must also include information indicated by other European legislation, such as:
- •Volatile organic compounds (Directive 2004/42/EC and amendments).
- •Labelling of detergents (Regulation (EC) No 648/2004 and amendments).
Which additional processes does the CLP Regulation include?
HARMONISED CLASSIFICATION AND LABELLING
The classification and labelling of certain hazardous chemicals are harmonised to ensure proper risk management throughout the European Union.
This classification is a classification of minimums and is included in Annex VI of the CLP Regulation (EC) No 1272/2008 (CLP).
C&L INVENTORY
The notification obligation in the CLP Regulation requires manufacturers and importers to submit information on the classification and labelling of the substances they place on the market to the C&L Inventory maintained by ECHA, which includes all the classifications for a given substance.