The CLP Regulation

In the European Union (EU), the majority of chemicals, in pure form or mixtures, must adhere to the CLP Regulation, which governs classification, notification, and product safety labeling. Accordingly, companies must comply with the CLP Regulation if they want to put their product on the European Union market.

What is the CLP Regulation?

The Classification, Labelling and Packaging (CLP) Regulation – (EC) No 1272/2008 – is based on the Globally Harmonised System (GHS) of the United Nations. Importantly, the goal of CLP regulation is to ensure a high degree of protection for human health and the environment, in addition to the free movement of chemicals, mixtures, and articles.

As of 1 June 2015, the CLP regulation amended the following three legislations and became the only piece of EU legislation in force governing the classification and labeling of substances and mixtures:

the Dangerous Substances Directive – 67/548/EEC (DSD);
the Dangerous Preparations Directive – 1999/45/EC (DPD); and
Regulation (EC) No 1907/2006 (REACH).

Generally speaking, the CLP Regulation:

Regulates communication of a hazardous substance or mixture through hazard labeling;
Establishes general packaging criteria to ensure the secure supply of hazardous substances or mixtures; and
Serves as the foundation of several legislative obligations regarding chemical risk management.

Complying with the CLP Regulation

The CLP Regulation is directly applicable to all industrial sectors and is legally obligatory throughout all Member States. Consequently, producers, importers, or downstream consumers of substances or mixtures must properly categorize, label, and package their hazardous chemicals before putting their products on the EU market.

Steps towards Compliance

Hazard classification is the first and most critical step of CLP. Its goal is to identify whether a substance in pure form or mixture has properties, according to its toxicological data or other relevant information, to be classified as hazardous. Notably, hazard classification is not based on exposure likelihood or risk factors.

2. If the substance in pure form or mixture satisfies the CLP classification criteria, the next step is to assign a specific hazard class and category. There are different hazard classifications under CLP regulation:

Physical hazard
Health hazard
Environmental hazard
Additional hazard

3. The last step is to disclose the identified hazards to other participants in the supply chain, including consumers. Hazard labeling, in addition to safety data sheets (SDS), enables manufacturers and importers to alert consumers to the presence of a hazard and the necessity to manage the associated risks. Hazard labeling elements include pictograms, signal words, and standard statements. These elements address hazard prevention, response, storage, and disposal. CLP establishes specific requirements for the labeling elements.

Moreover, manufacturers and importers must submit the information regarding hazard classification and labeling for the substances they are entering into the market to the C&L Inventory managed by the European Chemicals Agency (ECHA).

Hazard Labeling Elements under CLP

A hazard pictogram intends to alert consumers about the potential harm a specific substance or mixture can do to human health or the environment. The following table demonstrates examples of pictograms introduced by the CLP Regulation.

Pictogram	Description	Impacted products (examples)
	Hazardous to the environment Symbol: Environment	Batteries (e.g., Lead-acid) Biocides Pesticides Petrol Turpentine
	Corrosive Symbol: Corrosion	Batteries Welding Flux Acetic acid Ammoniac Drain cleaners Hydrochloric acid
	Health hazard/Hazardous to the ozone layer Symbol: Exclamation Mark	Adhesives Aerosol spray paint Batteries Solvents (e.g., Toluene) Coolant fluid Toilet cleaner Washing detergents
	Oxidising Symbol: Flame over circle	Batteries (e.g., Lead-acid) Bleach Medical purposes oxygen
	Serious health hazard Symbol: Health hazard	Aerosol spray paint Batteries Solvents (e.g., Toluene) Welding Flux Lamp oil Petrol Turpentine
	Acute toxicity Symbol: Skulls and Crossbones	Biocides Methanol Pesticides
	Flammable Symbol: Flame	Aerosol spray paint Solvents (e.g., Toluene) Lamp oil Nail polish remover Petrol
	Gas under pressure Symbol: Gas cylinder	Aerosol spray paint Gas containers Consumer goods (Fashion accessories)
	Explosive Symbol: Exploding bomb	Ammunition Fireworks

In addition to the pictograms, the label includes hazard statements explaining the potential impacts that the substance or mixture might have. Similarly, there are precautionary statements explaining how to use the product safely and what steps to take if you accidentally come into contact with it. Furthermore, the label contains a signal word that designates the degree of harm a product may cause: “Danger” for harm that is more severe and “Warning” for damage that is less severe.

Products bearing these labels could be harmful if not handled properly. Therefore, understanding what a label represents and adhering to the instructions is essential to guarantee safe use.

The Seveso Directive

The Seveso III Directive 2012/18/EU, which came into force on 1 June 2015, is regarding the control of major-accident hazardous and dangerous substances. This regulation outlines how to prevent significant industrial accidents that these substances could cause and mitigate the adverse effects of such accidents on human health and the environment. As a result, the Seveso III Directive imposes reporting obligations on facilities that carry out industrial operations involving hazardous substances. These establishments must provide the report to the national authorities of the appropriate Member State.

The Major Accident Hazards Bureau of the European Commission Joint Research Centre created the MINERVA portal, which includes information about significant mishaps that have happened within EU territory. Additionally, this portal contains information on current initiatives, pertinent publications, and methods for preventing severe chemical hazards.

Contact Enviropass if you have more questions about the CLP Regulation and how to comply with it.