Classification, Labelling & Packaging
according to the CLP Regulation
October 2021
Information Sheet
The Classification, Labelling and Packaging
(CLP) Regulation covers hazardous chemicals
sold to professional users and consumers.
This information sheet outlines the key
requirements under the CLP Regulation.
All hazardous chemicals (substances and mixtures) Exemptions from CLP
placed on the market must be classified, labelled
Waste is exempt from the CLP Regulation along with
and packaged according to the CLP Regulation
cosmetics, medicines, medical devices, veterinary
(EC) No. 1272/2008.
products, foodstuffs or animal feed which are in
In addition, substances imported on their own or in their finished state, intended for the final user.
a mixture require notification to the classification
and labelling inventory, within one month of
Classification of hazardous chemicals
placing on the market, while certain hazardous
mixtures require notification to the national The physical properties along with health and
poison centre, via the ECHA PCN portal, before environmental effects of chemicals must be
being placed on the market. identified and evaluated to determine if they
CLP requirements depend on the suppliers role in need to be classified. Some hazardous chemical
the supply chain. substances have legally harmonised (agreed)
hazard classifications which are listed in Annex VI of
The responsibility for classification of hazardous the CLP Regulation.
substances and mixtures lies with:
If a chemical substance does not have a hazard
• manufacturers of substances,
classification listed in Annex VI, then the
• importers of substances or mixtures, and
manufacturer or importer is legally obliged to
• formulators of mixtures.
examine all relevant available information against
The responsibility for labelling and packaging the CLP classification criteria and self classify the
of hazardous chemicals lies with all suppliers substance as hazardous when it meets the criteria.
including downstream users or distributors, who do
not reformulate or change the chemical, but relabel Similarly, formulators or importers of mixtures must
or repackage it. examine all relevant available information against
the CLP classification criteria and self classify as
The responsibility for notification to the
hazardous, where appropriate. For more
classification and labelling inventory lies with
information see Mixture Classification on the ECHA
the manufacturer or importer of the hazardous
website.
substance, regardless of tonnage, unless it is
already registered under REACH. Once the chemical’s hazards are identified,
The responsibility for notification to the poison communication of these hazards must be
centre lies with the importer or formulator of provided on the hazard label or directly
the mixture but , in certain cases, lies with the onto the packaging that meets
distributor if re-labelling/re-branding. the requirements of CLP.
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Classification, Labelling & Packaging according to the CLP Regulation
Information Sheet
Labelling of hazardous chemicals Layout and dimensions of
A hazard label must contain the following elements
the Hazard Label
applicable to hazardous chemicals placed on the The label must:
market as shown in figure 1: • be firmly attached to the surface of the
product,
• Name, address and telephone number of
• be visible, legible and readable in English, and
the EU supplier(s).
• have the following dimensions:
• Product identifiers e.g. chemical name and
CAS/EC no. of the substance/trade name of
a mixture along with the chemical name(s) Capacity of Dimensions Dimensions of
of all substances responsible for classification the package of label (mm) each pictogram
of the mixture (excluding skin and eye (mm)
irritants).
≤ 3 litres If possible at >10 x 10, if
• Hazard pictogram(s1):illustrates relevant least 52 x 74 possible > 16 x 16
hazard symbol.
• Signal word: either Warning or Danger > 3 litres but At least >23 x 23
≤ 50 litres 74 x 105
depending on the classification.
• Hazard statement(s) description of the > 50 litres but At least > 32 x 32
≤ 500 litres 105 x 148
hazardous effect e.g. Harmful if inhaled.
• The appropriate precautionary statements > 500 litres At least > 46 x 46
to allow the user of the chemical to take 148 x 210
measures to protect health/environment e.g.
Keep out of reach of children. • have all the hazard pictograms, signal word,
• Nominal quantity (when the chemical is hazard and precautionary statements
supplied to the general public). together, and readable horizontally when
• Supplemental information. set down normally,
• have, where more than one language is
Obligatory supplemental information includes used, all the hazard and precautionary
label elements such as the Unique Formula statements of the same language grouped
Identifier (UFI) or hazard statements taken from the together,
previous chemical legislation e.g. EUH001 Explosive • ensure that the hazard pictogram stands out
when dry and EUH204 Contains isocyanates. May clearly (black print on white background
produce an allergic reaction. surrounded by red frame being at least one
Non-obligatory supplemental labelling fifteenth and at least 1 cm2 of the label), and
information, for example, instructions for use is not • have no blank pictograms (where blank
part of the legal labelling requirements under CLP. pictograms are unavoidably printed on the
However, if provided it must not distract from nor label they should
contradict the obligatory label elements, hazard and be blacked out).
precautionary statements. Statements such as ‘non-
toxic’, ‘non-polluting’ may not be used on labels.
The hazard information on the label must be
consistent with the classification in Section 2.1
and the label elements in Section 2.2 of the Safety
Data Sheet (SDS) provided for the same chemical
product.
1
free of charge for download from the website [Link]
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WARNING
sed triangle which
n touched by a blind
rtially sighted person Classification, Labelling & Packaging according to the CLP Regulation
lerts them to the Information Sheet
azardous nature
of the product.
Figure 1: Example of Hazard Label for Supply
Product identifier – must be identical
PRODUCT
Hazard
to that used in the SDS. For substances
DENTIFIER this will be the chemical name and CAS
Pictograms –shaped
as a diamond with DANGER number or EC number.
black symbol on a
white background SUBSTANCE XYZ-123
Causes severe
with a red border. CAS No. xxxx-xx-x skin burns and Supplier
eye damage
HAZARD Must cover at least
one fifteenth of Wear protective
details –
name, address
TATEMENTS surface area of label, gloves…. and telephone
buthazards
ow the specific not be less than number.
1cm .
ciated with the chemical
2 IF SWALLOWED:
luding the nature and
Rinse mouth. Do
Supplier: XYZChem Ltd.
degree of hazard Danger NOT…. Cosy Lane, Unique
Signal word Flammable liquid and vapour Dublin 123
Rinse skin with
May be fatal if swallowed and enters airways Tel. No. 01 123 4567 Formula
Causes skin irritation water….. Identifier (UFI)
Hazard Statements May cause drowsiness or dizziness for use by
Toxic to aquatic life with long lasting effects poison centre
ECAUTIONARY
STATEMENTS
Precautionary Keep out of reach of children. CONTENTS
Keep away from heat/sparks/open flames/hot surfaces. – No smoking.
in event of
emergency.
Statements – Store in a well-ventilated place. Hydrochloric acid ..%
w the safeguards necessary
maximum of 6 on the Wear protective gloves/protective clothing/eye protection/face protection.
he protectionlabel.
of health and
All relevant IF SWALLOWED: Immediately call a POISON CENTER or doctor/physician. Do NOT induce
the environment.
precautionary vomiting. Name, Address & Nominal
statements should comfortable for breathing.
Telephone No. of
IF INHALED: Remove victim to fresh air and keep at rest in a position
quantity –
be in the SDS. required where
Manufacturer product is sold
to the general
NIQUE FORMULA
Non-obligatory UFI: VDU1-414F-1003-1862
2L public.
DENTIFIER (UFI)
supplemental infor-
mation – e.g. recy-
use by poison centre
cling in
information.
200ml
event of emergency
Unique Formula Identifier Updating the Hazard Label
Certain hazardous chemical products, classified The label should be updated without undue
with a physical or health hazard, not already delay, when there is a change in classification
notified to the National Poisons Information Centre of the substance or mixture which results in a
(NPIC) at Beaumont Hospital, requires a Unique more severe hazard or where new supplemental
Formula Identifier (UFI), on the label. This sixteen information is required on the label taking account
digit alpha-numeric number, should be notified of the nature of the change.
to the NPIC, via the European Chemicals Agency
PCN portal, before the product is placed on the Other required label changes, e.g. change in
Irish market. After notification, the NPIC should supplier address, shall be done within 18 months
also be notified directly regarding the use of their of the required change. Suppliers should cooperate
emergency number in Section 1.4 of the safety to ensure that labels are updated without undue
data sheet. delay.
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Classification, Labelling & Packaging according to the CLP Regulation
Information Sheet
Labelling of workplace chemicals Exemptions from labelling
The requirement for a CLP hazard label is Where packaging is either in such a shape or form
dependent on whether the chemical is being or so small as to not allow the necessary hazard
placed on the market or not, noting that import is labelling information to fit on the label, derogations
deemed to be ‘placing on the market’. exist. In such cases and where applicable, the label
elements may be provided either on:
All incoming or outgoing chemicals to or from a
workplace require a CLP hazard label if they are • fold-out labels,
classified as hazardous and being placed on the • tie-on tags, and/or
market. Therefore, all incoming chemicals to a • outer packaging.
workplace should be labelled by the supplier, and Certain labelling elements may be omitted where
all outgoing chemicals from a workplace equally the contents do not exceed 125ml, depending on
should be labelled before being placed on the the hazard classification of the substance or mixture.
market.
With the exception of biocides and plant protection
However, for chemicals produced and used within products, all label elements for certain hazard
a workplace the situation is different, because they classes which do not exceed 25ml may be omitted
are stored and transported within the workplace from soluble packaging for single use where the
and are not being placed on the market e.g. in label of the outer packaging is fully compliant.
containers and pipe work on site, so the CLP hazard
An exemption also applies for chemicals supplied
labelling rules do not apply.
for scientific research and development or
However, there is still a requirement to ensure a quality control analysis where the contents of
risk-based approach is undertaken to determine any the inner package do not exceed 10ml and where
potential hazards from such chemicals produced, the label of the outer packaging is fully compliant.
stored, transported and used within the workplace. See Section 1.5 Annex I of the CLP Regulation for
This may result in a requirement to produce an further details.
‘in-house’ hazard label.
Please see our Information Sheet on Selling hazardous chemical products
‘Communicating Chemical Hazards at Work’. online
When a supplier sells hazardous chemicals products
Unpackaged chemicals online, e.g. company website or on a marketplace
There is a provision under CLP for ‘wet cement’ platform (e.g. eBay), then the advert must include
which is sold to the general public without relevant hazard information. For example, if a
packaging. It must be accompanied by a copy of product is classified as irritating or sensitising to skin,
the label elements required under CLP (see part 5 then the advert should either include a copy of the
Annex II of the CLP Regulation for further details). hazard label (hazard pictograms/hazard statements)
or include the hazard information in the product
Derogations from labelling description. Including an image of the product
package (front and back) with a zoom function in
Derogations from hazard labelling requirements are the advert will suffice and if this is not possible,
permitted in special cases including transportable the information from the hazard label or Section
gas cylinders, gas containers intended for propane, 2.2 of the safety data sheet (SDS) for that product
butane or liquefied petroleum gas, certain aerosols, should be included into the product description.
certain mixtures containing elastomers and The requirement to include hazard information in
explosives. (See section 1.3 Annex I of the CLP online adverts only applies when a purchase can be
Regulation for further details). concluded online so does not apply when a website/
platform only offers a reserve/collect-in-store option,
as the sale is not concluded online.
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Classification, Labelling & Packaging according to the CLP Regulation
Information Sheet
Where a chemical comes under the scope of CLP and transport legislation and where the hazard pictograms
TACTILE
required are the same, then those pictograms under CLP do not need to appear on the packaging.
WARNING
Figure 2: Example of a Hazard Label for Supply and Transport
RaisedThis
triangle which of a single packaging label (e.g. a 200 litre drum) for a mixture classified under both transport
is an example
when touched by a blindTransport and CLP label elements must be shown on the packaging. The CLP pictograms for
and CLP criteria.
or partially
flammabilityperson
sighted and aquatic hazards (acute and chronic) have been omitted as the underlying hazards are already
alerts them to the
covered by the corresponding transport pictograms.
hazardous nature
of Transport
the [Link]/marks take precedence over a CLP pictogram on single packaging
Product identifiers - Trade name Transport label/marks – according
PRODUCT of mixture & identity of substances
contributing to classification of mixture.
to requirements for transport the minimum
size should be 100mm x 100mm.
IDENTIFIER
DANGER
Causes severe
CLEAN-MIX XYZ-123 Contains: Subs. X, Subs. Y skin burns and
Supply CAS No. xxxx-xx-x eye damage
HAZARD
Pictograms
Wear protective
STATEMENTS
– according gloves….
Show to the
[Link]
No hazards
associated withmarks
transport the chemical
IF SWALLOWED:
3
are required
including for and
the nature
Rinse mouth. Do
NOT…. Supplier
these hazards.
degree of hazard details –
Rinse skin with
UN9999
name, address
Danger water…..
[Proper Shipping Name]
and telephone
Flammable liquid and vapour
Signal word May be fatal if swallowed and enters airways Supplier: XYZChem Ltd. number.
PRECAUTIONARY CONTENTS
Causes skin irritation Cosy Lane,
May cause drowsiness or dizziness Dublin 123
STATEMENTS
Hazard Toxic to aquatic life with long lasting effects Tel. No. 01 123 4567
Hydrochloric acid ..% Unique
ShowStatements
the safeguards necessary
Keep out of reach of children. Formula
for the protection of health and
Keep away from heat/sparks/open flames/hot surfaces. – No smoking. Identifier (UFI)
the environment. Store in a well-ventilated place. Name, Address & for use by
Precautionary Telephone
Wear protective gloves/protective clothing/eye protection/face protection. No. of poison centre
Statements – IF SWALLOWED: Immediately call a POISON CENTER or doctor/physician. Do NOT induce
in event of
maximum of 6 vomiting. Manufacturer emergency.
IF INHALED: Remove victim to fresh air and keep at rest in a position
on the label. All comfortable for breathing.
UNIQUE FORMULA
relevant UFI: VDU1-414F-1003-1862
IDENTIFIER
precautionary (UFI)Contact with water liberates toxic gas 200L
statements
For should
use by poison centre in
200ml
event of emergency
be in the SDS. Obligatory supplemental
information – EUH029
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Classification, Labelling & Packaging according to the CLP Regulation
Information Sheet
Hazard Labels for Supply and Transport When sold to the general public the packaging
should not have either a shape or a design that
Substance and mixtures which are not required to
would attract or arouse the active curiosity of
be classified and labelled under the provisions of the
children or be misleading to consumers. It should
transport of dangerous goods need to still display
not have a similar presentation or design to that
CLP labels on the inner, intermediate and outer
is used in foodstuff, animal feed, medicines or
packaging. However, where suppliers, including
cosmetics.
distributors, include additional layers of packaging,
to protect supply packages during transport or Note: Packaging that meets the requirements of the rules of
the transport of dangerous goods shall be deemed to meet
consolidation of several different supply packages
most of the provisions of the CLP Regulation.
into a larger box for transport, such packaging is
considered to be outside the scope of CLP and does
not require a CLP label. See Section 5.4.2 of the Further Information
ECHA labelling and packaging guidance for more • National Poison Information Centre web pages:
information. [Link].
• The Health and Safety Authority’s Chemicals
web pages: [Link]/chemicals.
Packaging of hazardous chemicals
• E-mail the HSA’s Chemicals Helpdesk:
Packaging should be designed so the hazardous
chemicals@[Link].
contents cannot escape, except where more
specific safety devices are required to be in place. • European Chemicals Agency’s (ECHA)
Therefore, the packaging material shall not be Publication: Guidance on labelling and
suspectable to damage by its contents and should packaging in accordance with the CLP
Regulation.
be strong enough throughout to meet the normal
stresses and strains of handling. • Q&A Support on ECHAs website.
Depending on the classification of the substance
or mixture child-resistant fastenings and tactile HSA Publications
warnings of danger are required for certain • Chemical Distributors Information Sheet.
hazardous chemicals. Details of which is set out in
• Communicating hazards at work.
Annex II of CLP.
• Information for Retailers on Hazard
Replaceable fastenings should be designed so that Labelling & Packaging of Chemical
they can be repeatedly refastened without the Products.
contents escaping.
• Safety Data Sheets for Hazardous
Chemicals.
• Chemical Importers Information Sheet.
Further Information and Guidance:
Visit our website at [Link] , telephone
our contact centre on 1890 289 389 or
email wcu@[Link]
Use BeSMART, our free online risk assessment tool at [Link]
Check out our range of free online courses at [Link]
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