Q.01

What is the CLP regulation?

The CLP Regulation is Regulation (EC) No 1272/2008 on the classification, labelling and packaging of substances and mixtures. It is the EU law that sets common criteria for identifying chemical hazards and the rules for communicating them on labels and packaging. Its stated purpose is "to ensure a high level of protection of human health and the environment as well as the free movement of substances, mixtures and articles" [1].

Approach: I read Articles 1 and 4 of the current consolidated text of Regulation (EC) No 1272/2008 (consolidated version dated 1 July 2026). Great Britain applies its own retained version of CLP, which I did not cover here.

What it does (Article 1(1)) [1]

  • Common criteria: it harmonises the criteria for classifying substances and mixtures, and the labelling and packaging rules for hazardous ones.
  • Duty to classify: manufacturers, importers and downstream users must classify substances and mixtures they place on the market.
  • Duty to label and package: suppliers must label and package what they place on the market.
  • Unmarketed substances: manufacturers, producers of articles and importers must also classify substances that are not placed on the market but need REACH registration or notification (Regulation (EC) No 1907/2006).
  • Notification to ECHA: manufacturers and importers must notify the Agency of classifications and label elements, unless these were already submitted in a REACH registration.
  • Harmonised list: Part 3 of Annex VI lists substances with harmonised (EU-wide) classifications.
  • C&L Inventory: it sets up a classification and labelling inventory made up of all these notifications, submissions and harmonised classifications.

Core obligations (Article 4) [2]

  • Classify before sale: manufacturers, importers and downstream users "shall classify" substances or mixtures under Title II before placing them on the market.
  • Annex VI entries take priority: if a substance has an entry in Annex VI Part 3, it "shall be classified in accordance with that entry". Companies still self-classify any hazard classes, forms or physical states that the entry does not cover.
  • Label and package hazardous products: suppliers must label and package them under Titles III and IV, and suppliers in a supply chain "shall cooperate" to meet these requirements.
  • Non-compliant products banned: substances and mixtures "shall not be placed on the market unless they comply with this Regulation".
  • EU-based supplier: a supplier established in the Union must fulfil the requirements and be identified on the label.

What it does not cover (Article 1(2), (3), (5) and (6)) [1]

  • Radioactive substances and mixtures.
  • Goods under customs supervision that are not treated or processed (temporary storage, free zones, transit).
  • Non-isolated intermediates.
  • Substances and mixtures for scientific research and development that are not placed on the market and are used under controlled conditions.
  • Waste.
  • Finished products intended for the final user that are:
    • medicinal or veterinary medicinal products,
    • cosmetic products,
    • certain medical devices (invasive or in direct contact with the body, plus in vitro diagnostics),
    • food or feed.
  • Transport of dangerous goods by air, sea, road, rail or inland waterways. That falls under the separate transport rules, except where Article 33 (packaging marked for both transport and supply) applies.

Member States may also allow exemptions for certain substances or mixtures in specific cases where defence requires it.

I can go into any part of the Regulation in more detail, for example the hazard classes in Annex I, label elements, poison-centre notification under Annex VIII, or a substance's Annex VI entry.

Q.02

How is it different from GHS and the old CHIP rules?

CLP is the EU law that puts the UN's Globally Harmonised System (GHS) into binding EU legislation. It takes GHS hazard classes and label elements but adds EU-only hazards, so it is not a copy of GHS. In the EU it replaced the old Dangerous Substances Directive (67/548/EEC) and Dangerous Preparations Directive (1999/45/EC), which were repealed on 1 June 2015. CHIP was the UK's set of rules from that older system, and HSE says CLP replaced it on the same date.

Approach: I read the recitals and transitional articles of Regulation (EC) No 1272/2008 (the 2008 base act and the consolidated text dated 1 July 2026) and the 2023 amending act, Regulation (EU) 2023/707. CHIP itself is not in the datasets, so the CHIP points come from HSE's own guidance page.

CLP compared with GHS

  • Where each comes from: The GHS is a set of classification and labelling criteria "carefully developed over a period of 12 years within the United Nations (UN) structure" [3]. CLP is how the EU incorporates "the internationally agreed GHS criteria into Community law" [4].
  • What CLP takes from GHS:
    • The GHS hazard classes and definitions [5].
    • The core label elements: pictograms, signal words, hazard statements and precautionary statements [6].
  • Where CLP goes beyond GHS:
    • Older EU hazards kept: CLP keeps "Community hazard classes not yet part of the GHS" from the old directives so that the existing level of protection is maintained [7][8].
    • EU-specific label information: Article 25 requires supplemental statements on the label. It also requires any supplemental hazard statements listed for the substance in Annex VI. These are EU additions on top of the GHS label elements [9].
    • New EU-only hazard classes (2023): Regulation (EU) 2023/707 added hazard classes for endocrine disruptors, PBT/vPvB and PMT/vPvM substances [10]. Their EUH statements "should function as 'H-statements'" [11]. Pictograms for them are to be added only once the UN GHS adopts them [12].
  • Keeping up with GHS: The GHS is revised periodically at UN level [13]. The Commission is empowered to bring those UN amendments into CLP through technical adaptations [14].

CLP compared with the old rules (DSD/DPD in the EU, CHIP in the UK)

  • Repeal date: Directives 67/548/EEC and 1999/45/EC "shall be repealed with effect from 1 June 2015" (Article 60) [15].
  • Staged switchover (Article 61) [16]:
    • Substances followed the old Directive until 1 December 2010.
    • From then until 1 June 2015, substances had to be classified under both systems but labelled under CLP.
    • Mixtures moved to CLP on 1 June 2015.
    • Stock already on the market had extra time before relabelling: until 1 December 2012 for substances and until 1 June 2017 for mixtures.
  • Converting old classifications: Companies may convert old classifications using the conversion table in Annex VII [16]. The harmonised classifications in Annex I of Directive 67/548/EEC were converted to the new criteria [17].
  • What changed on the label, per HSE (HSE: COSHH, CLP and REACH):
    • The CLP pictograms are "very similar to the CHIP hazard symbols" but have a new shape, design and colour.
    • Hazard statements replace the CHIP risk phrases.
    • Precautionary statements replace the CHIP safety phrases.
    • A signal word, 'warning' or 'danger', is added depending on how severe the hazard is.

In Great Britain today, the rules are GB CLP, the retained version of the Regulation. Its recitals keep the same GHS-based approach to label elements [18].

Sources:

Q.03

Which CLP rules apply in Great Britain and Northern Ireland?

Great Britain (England, Scotland and Wales) uses GB CLP, which is the assimilated Regulation (EC) No 1272/2008 as amended for GB, with HSE acting as the "Agency". Northern Ireland still applies the EU CLP Regulation under the Northern Ireland Protocol and Windsor Framework. There is one overlap: an NI business that supplies "qualifying Northern Ireland goods" directly to the GB market has to meet GB CLP for those goods.

Approach: I read the GB CLP text as it applies in Great Britain, the EU CLP consolidated text and its amending acts, and the GB mandatory classification and labelling (MCL) list. The legal texts don't explain how the regimes are split across the UK, so that part comes from HSE and HSENI guidance.

Great Britain: GB CLP

  • Scope: HSE says GB CLP has regulated classification, labelling and packaging of chemicals placed on the GB market since 1 January 2021 (HSE, CLP in GB or NI).
  • Who the duties fall on:
    • Manufacturer, importer, downstream user and distributor are defined by reference to Great Britain [19][20].
    • "Import" means physical introduction into Great Britain, "except where the goods are qualifying Northern Ireland goods" [19].
    • "The Agency" means the Health and Safety Executive [20].
  • Same core duties as EU CLP: Article 4 keeps the obligations to classify, label and package. A substance with an entry in the GB MCL list "shall be classified in accordance with that entry", and companies self-classify only the hazard classes the entry does not cover [21].
  • GB MCL list instead of Annex VI:
    • HSE "must establish, maintain and publish" the list (Article 38A) [22].
    • Under Article 37, new entries follow this route [23][24]:
      • HSE publishes a technical report and an opinion.
      • HSE sends a recommendation to the Secretary of State, who decides on it.
      • Proposals from a territory (including the EU) that has adopted the GHS in a similar way to the UK can be handled as "fast-track proposals".
    • HSE says all EU harmonised classifications in force on 31 December 2020 were carried over as GB MCL (HSE, The GB CLP Regulation).
  • Labels: Labels "shall be written in English", and extra languages are allowed if they carry the same details (Article 17(2)) [25].
  • Poison centres: The Secretary of State (for England) and the Devolved Authorities appoint the bodies that receive emergency health response information (Article 45) [26].
  • Technical updates: The Secretary of State may amend the Annexes "by regulations", taking account of GHS developments (Article 53) [27].

Northern Ireland: EU CLP

  • Which law applies: HSENI says "the EU CLP Regulation will apply in Northern Ireland" from 1 January 2021 (HSENI).
  • Notifications: NI businesses notify ECHA, not HSE, for the EU Classification and Labelling Inventory (same HSENI page).
  • Harmonised classifications: Annex VI of EU CLP applies, not the GB MCL list.
  • EU amendments apply in NI but not GB: Regulation (EU) 2024/2865 is one example. It sets minimum font sizes and label dimensions and allows fold-out labels [28]. EU Article 31 now permits fold-out and digital labels [29]. GB Article 31 has no such provision [30].

Goods moving between GB and NI

  • NI to GB (qualifying NI goods):
    • GB CLP extends some of its definitions (manufacturer, producer of an article, downstream user, distributor) to NI-established businesses whose qualifying NI goods are "placed directly on the market in Great Britain" [19][20].
    • HSENI says these businesses must "classify, label and package the chemical according to GB requirements" and notify HSE where the criteria are met.
    • Article 37(7) says NI businesses supplying qualifying NI goods directly to GB are not covered by paragraph 6(b) and (c) [24]. Those two points give GB manufacturers, importers and downstream users the option, and in (c) the duty, to send MCL classification proposals to HSE [23].
  • GB to NI: The product must comply with EU CLP. HSE says the obligations sit with the NI-based business that imports the substances or mixtures, not with the GB supplier (HSE, CLP in GB or NI).

Sources:

Q.04