CLP Regulation – Guide to Classification and Labelling

The CLP Regulation (EC) No 1272/2008 (Classification, Labelling and Packaging) is the central European regulatory framework for the classification, labelling and packaging of chemical substances and mixtures. It transposes the United Nations' Globally Harmonized System (GHS) into EU law and has been mandatory since 1 June 2015 for all chemical products placed on the EU market. The CLP Regulation replaces the former Directives 67/548/EEC (substances) and 1999/45/EC (preparations) and introduces uniform hazard pictograms, signal words, and H and P statements. The aim is the protection of people and the environment through clear, internationally understandable hazard communication.

Classification & Labelling

Classification is based on the intrinsic properties of a substance or mixture. Manufacturers and importers must examine, based on available data, whether a substance exhibits physical, health or environmental hazards and classify it according to the criteria of the CLP Regulation.

Hazard Classes

The CLP Regulation defines 28 hazard classes in three main groups: physical hazards (e.g. flammable liquids, explosive substances, oxidizing substances), health hazards (e.g. acute toxicity, skin corrosion, carcinogenicity) and environmental hazards (e.g. hazardous to the aquatic environment). Each class is subdivided into categories indicating the severity of the hazard.

Signal Words

"Danger" is used for severe hazard categories, "Warning" for less severe ones. Each classification receives exactly one signal word – or none, if the hazard category does not provide for one.

GHS Pictograms

Nine red-bordered diamonds with a black symbol on a white background replace the former orange hazard symbols. Each pictogram represents a specific hazard group – from the skull and crossbones (acute toxicity) to the flame (flammability) to the environmental hazard (dead tree and fish).

GHS Pictograms explained

H-Statements – Hazard Statements

H-Statements (Hazard Statements) describe the nature and severity of a hazard. They consist of the letter H followed by a three-digit number: H2xx for physical hazards, H3xx for health hazards and H4xx for environmental hazards. Unlike the old R-phrases, H-Statements are standardized worldwide.

All H-Statements at a glance

P-Statements – Precautionary Statements

P-Statements (Precautionary Statements) recommend measures to minimize risks. They are divided into five categories: general (P1xx), prevention (P2xx), response (P3xx), storage (P4xx) and disposal (P5xx). P-Statements replace the former S-phrases of the EU directive.

All P-Statements at a glance

R→H Conversion Table

The following table shows the assignment of old R-phrases (risk phrases) to new H-Statements under the CLP Regulation, Annex VII. Note that the assignment is not always one-to-one – one R-phrase may correspond to multiple H-Statements.

R1

Explosive when dry.

Explosive; mass explosion hazard.

R2

Risk of explosion by shock, friction, fire or other sources of ignition.

Explosive; mass explosion hazard.

R3

Extreme risk of explosion by shock, friction, fire or other sources of ignition.

Explosive; mass explosion hazard.

R5

Heating may cause an explosion.

Heating may cause a fire or explosion.

R6

Explosive with or without contact with air.

Unstable explosive.

R7

May cause fire.

Heating may cause a fire.

R8

Contact with combustible material may cause fire.

May cause fire or explosion; strong oxidiser.

R9

Explosive when mixed with combustible material.

May cause fire or explosion; strong oxidiser.

R10

Flammable.

Flammable liquid and vapour.

R11

Highly flammable.

Highly flammable liquid and vapour.

R12

Extremely flammable.

Extremely flammable liquid and vapour.

R14

Reacts violently with water.

In contact with water releases flammable gases which may ignite spontaneously.

R15

Contact with water liberates extremely flammable gases.

In contact with water releases flammable gases.

R17

Spontaneously flammable in air.

Catches fire spontaneously if exposed to air.

R18

In use, may form flammable/explosive vapour-air mixture.

Highly flammable liquid and vapour.

R20

Harmful by inhalation.

Harmful if inhaled.

R21

Harmful in contact with skin.

Harmful in contact with skin.

R22

Harmful if swallowed.

Harmful if swallowed.

R23

Toxic by inhalation.

Toxic if inhaled.

R24

Toxic in contact with skin.

Toxic in contact with skin.

R25

Toxic if swallowed.

Toxic if swallowed.

R26

Very toxic by inhalation.

Fatal if inhaled.

R27

Very toxic in contact with skin.

Fatal in contact with skin.

R28

Very toxic if swallowed.

Fatal if swallowed.

R29

Contact with water liberates toxic gas.

In contact with water releases flammable gases which may ignite spontaneously.

In contact with water releases flammable gases.

R34

Causes burns.

Causes severe skin burns and eye damage.

R35

Causes severe burns.

Causes severe skin burns and eye damage.

R36

Irritating to eyes.

Causes serious eye irritation.

R37

Irritating to respiratory system.

May cause respiratory irritation.

R38

Irritating to skin.

Causes skin irritation.

R39

Danger of very serious irreversible effects.

Causes damage to organs.

R40

Limited evidence of a carcinogenic effect.

Suspected of causing cancer.

R41

Risk of serious damage to eyes.

Causes serious eye damage.

R42

May cause sensitization by inhalation.

May cause allergy or asthma symptoms or breathing difficulties if inhaled.

R43

May cause sensitization by skin contact.

May cause an allergic skin reaction.

R45

May cause cancer.

May cause cancer.

R46

May cause heritable genetic damage.

May cause genetic defects.

R48

Danger of serious damage to health by prolonged exposure.

Causes damage to organs through prolonged or repeated exposure.

May cause damage to organs through prolonged or repeated exposure.

R49

May cause cancer by inhalation.

May cause cancer.

R50

Very toxic to aquatic organisms.

Very toxic to aquatic life.

R51

Toxic to aquatic organisms.

Toxic to aquatic life with long lasting effects.

R52

Harmful to aquatic organisms.

Harmful to aquatic life with long lasting effects.

R53

May cause long-term adverse effects in the aquatic environment.

May cause long lasting harmful effects to aquatic life.

R60

May impair fertility.

May damage fertility or the unborn child.

R61

May cause harm to the unborn child.

May damage fertility or the unborn child.

R62

Possible risk of impaired fertility.

Suspected of damaging fertility or the unborn child.

R63

Possible risk of harm to the unborn child.

Suspected of damaging fertility or the unborn child.

R64

May cause harm to breastfed babies.

May cause harm to breast-fed children.

R65

Harmful: may cause lung damage if swallowed.

May be fatal if swallowed and enters airways.

R68

Possible risk of irreversible effects.

Suspected of causing genetic defects.

May cause damage to organs.

S→P Conversion Table

This table shows the assignment of old S-phrases (safety advice) to new P-Statements under the CLP Regulation. Here too, the assignment is not always unambiguous.

S1

Keep locked up.

Store locked up.

S2

Keep out of the reach of children.

Keep out of reach of children.

S3

Keep in a cool place.

Store in a well-ventilated place.

S7

Keep container tightly closed.

Keep container tightly closed.

S9

Keep container in a well-ventilated place.

Store in a well-ventilated place.

S13

Keep away from food, drink and animal feeding stuffs.

Do not eat, drink or smoke when using this product.

S16

Keep away from sources of ignition – No smoking.

Keep away from heat, hot surfaces, sparks, open flames and other ignition sources. No smoking.

S17

Keep away from combustible material.

Keep away from clothing and other combustible materials.

S20

When using do not eat or drink.

Do not eat, drink or smoke when using this product.

S22

Do not breathe dust.

Do not breathe dust/fume/gas/mist/vapours/spray.

S23

Do not breathe gas/fumes/vapour/spray.

Do not breathe dust/fume/gas/mist/vapours/spray.

S24

Avoid contact with skin.

Wash hands thoroughly after handling.

Wear protective gloves/protective clothing/eye protection/face protection.

S25

Avoid contact with eyes.

Wash hands thoroughly after handling.

Wear protective gloves/protective clothing/eye protection/face protection.

In case of contact with eyes, rinse immediately with plenty of water and seek medical advice.

IF IN EYES:

Rinse cautiously with water for several minutes.

Remove contact lenses, if present and easy to do. Continue rinsing.

S27

Take off immediately all contaminated clothing.

Take off immediately all contaminated clothing.

S28

After contact with skin, wash immediately with plenty of water.

IF ON SKIN:

Wash with plenty of water.

S33

Take precautionary measures against static discharges.

Ground and bond container and receiving equipment.

Use explosion-proof electrical/ventilating/lighting equipment.

S35

This material and its container must be disposed of in a safe way.

Dispose of contents/container in accordance with local/regional/national/international regulations.

S36

Wear suitable protective clothing.

Wear protective gloves/protective clothing/eye protection/face protection.

S37

Wear suitable gloves.

Wear protective gloves/protective clothing/eye protection/face protection.

S38

In case of insufficient ventilation, wear suitable respiratory equipment.

Wear protective gloves/protective clothing/eye protection/face protection.

S39

Wear eye/face protection.

Wear protective gloves/protective clothing/eye protection/face protection.

S45

In case of accident or if you feel unwell, seek medical advice immediately.

IF exposed or concerned:

Immediately call a POISON CENTER/doctor.

If swallowed, seek medical advice immediately and show this container or label.

IF SWALLOWED:

Immediately call a POISON CENTER/doctor.

If medical advice is needed, have product container or label at hand.

S50

Do not mix with …

Keep away from clothing and other combustible materials.

S51

Use only in well-ventilated areas.

Do not breathe dust/fume/gas/mist/vapours/spray.

Store in a well-ventilated place.

S56

Dispose of this material and its container at hazardous or special waste collection point.

Dispose of contents/container in accordance with local/regional/national/international regulations.

S57

Use appropriate containment to avoid environmental contamination.

Avoid release to the environment.

S59

Refer to manufacturer/supplier for information on recovery/recycling.

Dispose of contents/container in accordance with local/regional/national/international regulations.

S61

Avoid release to the environment. Refer to special instructions/safety data sheet.

Avoid release to the environment.

Collect spillage.

If swallowed, do not induce vomiting. Seek medical advice immediately.

IF SWALLOWED:

Do NOT induce vomiting.

Immediately call a POISON CENTER/doctor.

Obligations for Companies

The CLP Regulation obliges all actors in the supply chain to properly classify, label and package chemical substances and mixtures.

Manufacturers & formulators

Manufacturers and formulators must classify their substances and mixtures before placing them on the market, label them with the correct hazard pictograms, signal words, H and P statements, and notify the classification to ECHA (C&L inventory).

Importers

Importers who bring substances or mixtures into the EU bear the same obligations as manufacturers. They must ensure that labelling complies with CLP requirements before the product is placed on the market.

Safety Data Sheet

The CLP classification must be documented in the Safety Data Sheet (SDS, Section 2). The REACH Regulation and CLP Regulation are closely linked: any change in classification requires an updated SDS.

Frequently Asked Questions about the CLP Regulation

What is the difference between CLP and GHS?

GHS (Globally Harmonized System) is the worldwide UN framework for the classification and labelling of chemicals. CLP is the EU regulation that transposes GHS into European law. CLP contains some EU-specific adaptations but fundamentally follows the GHS criteria. In practice, the terms are often used interchangeably.

Are R-phrases and S-phrases still valid?

No. Since 1 June 2015, only the H and P statements of the CLP Regulation apply. The old R and S phrases of Directives 67/548/EEC and 1999/45/EC have been fully replaced. Existing stocks with old labelling may no longer be placed on the market.

Who is responsible for classification?

The responsibility lies with the manufacturer, importer or downstream user who places a substance or mixture on the market. For certain particularly hazardous substances, there are harmonised classifications (Annex VI of the CLP Regulation) that are legally binding.

What is a harmonised classification?

A harmonised classification is an EU-wide binding classification of a substance, listed in Annex VI of the CLP Regulation. It applies to particularly hazardous substances (CMR substances, respiratory sensitisers) and takes precedence over self-classification by the manufacturer.

Where can I find the official CLP Regulation?

The consolidated version of CLP Regulation (EC) No 1272/2008 is available on EUR-Lex, the official legal portal of the EU. Additionally, ECHA (European Chemicals Agency) provides guidance documents and tools for the practical implementation of CLP requirements.

Further Resources

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