REGAFFAIRS AI
Guide · 2026-11-05 · 4 min

Annex VI CLP entries and harmonised classification explained

Annex VI CLP lists harmonised substance classifications. Find the right Table 3 entry, read its notes and check application dates before using it.

Annex VI CLP contains EU rules for the harmonised classification and labelling of certain hazardous substances. Suppliers must use the applicable Table 3 entry for covered hazards and forms, then classify those outside its scope. Article 4(3) sets this duty.

The list is not a register of every hazardous substance. A blank hazard field does not mean "not hazardous", and a failed CAS-number search does not exclude a group entry. For regulatory and SDS teams, finding a name is only the start: the entry's scope and notes determine how to use it. Annex VI explains these limits.

Where to find Annex VI of the CLP Regulation

Start with ECHA's Annex VI resource. Its spreadsheet helps with lookups, but it is unofficial. The Official Journal text and subsequent amendments are the legally binding sources.

The consolidated CLP text on EUR-Lex brings provisions together for reference. It is a documentation tool, not an authentic legal act. Check the relevant amendment and its application date before relying on an entry.

Annex VI has three parts. Part 1 explains the entries and notes; Part 2 sets principles for harmonised classification and labelling dossiers. Part 3, Table 3 contains the list of harmonised classification and labelling of hazardous substances. These divisions appear in the Annex VI introduction.

How to find the right Table 3 entry

Use the substance name, EC number and CAS number to start the search. Then check the Index number and full chemical description against your substance. Do not rely on a matching name alone. Part 1 gives the identification rules.

If there is no individual match, check group entries and their exclusions. Groups covering more than four individual substances usually have no EC or CAS number. This makes identifier-only searches an easy way to miss an applicable classification. Where several group entries apply, consider their classifications together. For conflicting classifications of the same hazard, use the most severe, subject to the entry wording. See section 1.1.1.5.

Check the physical form, hydration, purity and impurity wording next. Salt entries cover anhydrous and hydrated forms unless stated otherwise. Under Article 4(3), an entry applies to all forms or physical states unless it specifies otherwise. Read any limitations before carrying the classification into your assessment. The legal text covers both scope and identification.

Keep company notifications separate from harmonised entries. The broader C&L Inventory includes both types of information. A company's notified classification is not interchangeable with the legally harmonised classification required by Article 4(3).

How to read a harmonised classification entry

Read across the whole row, including the notes. Annex VI sections 1.1.1–1.1.3 explain the fields below.

FieldWhat to check
Index numberEntry identifier, in the format ABC-RST-VW-Y.
Chemical name, EC and CAS numbersSubstance identity, group scope and qualifications.
ClassificationHazard class/category codes and hazard-statement codes.
LabellingPictograms, signal word, hazard statements and supplemental statements. Dgr means Danger; Wng means Warning.
SCLs, M-factors and ATEsValues used when classifying mixtures containing the substance.
NotesConditions affecting identity, classification, labelling or mixture calculations.

Specific concentration limits (SCLs) listed for mixture classification must be used. Where no SCL is given for a category, the relevant generic limits apply. Notes can change the concentration basis or calculation. Section 1.1.2.3 and the notes explain their use.

M-factors multiply contributions in aquatic-hazard mixture summation for Aquatic Acute 1 or Chronic 1 substances. Preserve any acute/chronic distinction. Acute toxicity estimates (ATEs) support the mixture additivity formula: retain their exposure route and units. Missing values do not justify assuming an M-factor of 1 or inventing an ATE. Establish the appropriate value from available data under the CLP provisions.

An asterisk needs context. Beside a classification category, a single asterisk denotes a minimum classification inherited from older rules. More severe classification is required when the specified data conditions are met. In the SCL/M-factor/ATE column, a single asterisk has a different legacy meaning and is not a numerical SCL. Do not treat every harmonised classification as a minimum classification. See sections 1.2.1–1.2.4.

How harmonised classification and labelling changes Annex VI

ECHA describes the CLH process as intention, dossier submission, accordance check, consultation and development of a Risk Assessment Committee (RAC) opinion. A Commission decision and inclusion in Annex VI follow. Neither a proposal nor a RAC opinion is itself an enacted amendment.

ECHA consultations normally last 60 days, unless specified otherwise. Comments concern the hazard classes open for consultation. Article 37 provides for a RAC opinion within 18 months of receiving a proposal. That is not a guarantee of mandatory application within 18 months of an initial intention. Check the legal process separately from the application date.

For example, Regulation (EU) 2025/1222 has a general application date of 1 February 2027. It permits earlier use from entry into force. As of 5 November 2026, that general application date is still ahead. A published amendment or downloadable workbook therefore does not, by itself, establish what is already mandatory.

Does Annex VI apply in the UK?

For England, Scotland and Wales, check the legally binding GB Mandatory Classification and Labelling List. Do not assume EU amendments apply automatically in Great Britain. HSE states that EU CLP regulates classification in Northern Ireland under the Northern Ireland Protocol/Windsor Framework.

RegAffairs AI's answer explains harmonised classification and how to find a substance entry.

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