EU CLP Regulation: who classifies, labels and notifies chemical products, and what the 2024 revision changed

CLP is the EU’s version of the UN GHS

The United Nations built one worldwide set of criteria for classifying and labelling chemicals: the Globally Harmonised System of Classification and Labelling of Chemicals, the GHS (recital 5 of Regulation (EC) No 1272/2008Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027The whole regulationClick opens the law on the EU Publications Office.). CLP writes the GHS criteria into EU law (recital 6). It also keeps EU hazard classes “not yet part of the GHS” and the EU’s earlier labelling rules (recital 8). Those show on labels as EUH statements. One example is EUH208, “Contains (name of sensitising substance). May produce an allergic reaction”, on a mixture not classified as sensitising that still holds a sensitising substance at or above the limit in Annex I, Table 3.4.6 (Annex II, section 2.8).

When was CHIP replaced by CLP? In the EU, CLP replaced two older directives, 67/548/EEC on dangerous substances and 1999/45/EC on dangerous preparations. Both were repealed with effect from 1 June 2015 (Art. 60Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 60Click opens the article on EUR-Lex.). In the UK those directives had been put into law by the Chemicals (Hazard Information and Packaging for Supply) Regulations 2009, known as CHIP. CHIP’s classification, labelling and packaging duties were revoked with effect from 1 June 2015. Its last provisions, including the duty to keep records on dangerous preparations, went on 1 June 2018 (regulation 36 of S.I. 2013/1506).

EU CLP and GB CLP are two laws. After Brexit the EU text was kept in the law of Great Britain, with changes, as the GB CLP Regulation. In Great Britain HSE runs it. A substance or mixture placed on the market in Northern Ireland follows the EU CLP Regulation (HSE, The GB CLP Regulation).

Which products CLP covers, and which it leaves out

CLP covers substances and mixtures placed on the EU market. “Placing on the market” means supplying it to anyone else, paid or free; import counts as placing on the market (Art. 2(18)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 2, point 18Click opens the article on EUR-Lex.).

The exclusions for cosmetics, medicines, medical devices and food apply to the product “in the finished state, intended for the final user” (Art. 1(5)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 1, paragraph 5Click opens the article on EUR-Lex.). A bulk fragrance oil sold to a soap or cosmetics maker is not a finished cosmetic, so CLP covers it.

Who must classify, label and notify

CLP calls every manufacturer, importer, downstream user and distributor that places a substance or mixture on the market a “supplier” (Art. 2(26)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 2, point 26Click opens the article on EUR-Lex.). Each role carries its own set of duties. All four roles are defined as businesses established in the EU (Art. 2(15)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 2, point 15Click opens the article on EUR-Lex., Art. 2(17)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 2, point 17Click opens the article on EUR-Lex., Art. 2(19)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 2, point 19Click opens the article on EUR-Lex., Art. 2(20)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 2, point 20Click opens the article on EUR-Lex.).

Suppliers in a chain cooperate to meet CLP (Art. 4(9)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 4, paragraph 9Click opens the article on EUR-Lex.). In practice your supplier’s safety data sheet carries the classification and the label elements in its section 2 (Annex II, section 2, of REACH). How the two documents fit together is set out in safety data sheet requirements.

How a product is classified

A substance or mixture that meets the criteria for a physical, health or environmental hazard in Parts 2 to 5 of Annex I is hazardous, and is classified in the matching hazard class (Art. 3Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 3Click opens the article on EUR-Lex.). A hazard class is “the nature of the physical, health or environmental hazard”; a hazard category is the severity within that class (Art. 2(1)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 2, point 1Click opens the article on EUR-Lex., Art. 2(2)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 2, point 2Click opens the article on EUR-Lex.).

The steps are set by Title II:

1. Find the information. Test data, human experience, and any other relevant information on the substance, or on the mixture and the substances in it (Art. 5(1)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 5, paragraph 1Click opens the article on EUR-Lex., Art. 6(1)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 6, paragraph 1Click opens the article on EUR-Lex.).
2. Apply the criteria. Compare that information with the criteria of each hazard class in Annex I (Art. 9(1)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 9, paragraph 1Click opens the article on EUR-Lex.). A mixture without test data of its own is classified from similar tested mixtures through the bridging principles, or from the substances in it (Art. 9(4)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 9, paragraph 4Click opens the article on EUR-Lex.).
3. Count what is in it. A hazardous substance in a mixture counts once it reaches its cut-off value (Art. 11Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 11Click opens the article on EUR-Lex.). Concentration limits decide at what level it makes the mixture hazardous (Art. 10(1)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 10, paragraph 1Click opens the article on EUR-Lex.).
4. Decide. Assign a hazard category and a hazard statement for each hazard class met (Art. 13Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 13Click opens the article on EUR-Lex.). The label elements follow from that.
5. Review. Re-evaluate without undue delay when you learn of new, reliable information (Art. 15(1)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 15, paragraph 1Click opens the article on EUR-Lex.), and when you change a hazardous mixture’s recipe beyond the limits in Art. 15(2)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 15, paragraph 2Click opens the article on EUR-Lex..

Annex VI harmonised classifications override your own

Part 3 of Annex VI lists substances with a classification agreed at EU level. Where a substance has such an entry, it is classified in line with that entry, and nobody classifies it differently for the hazard classes the entry covers (Art. 4(3)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 4, paragraph 3Click opens the article on EUR-Lex.). You still classify it for any other hazard class, or for a form or physical state the entry does not cover. You may not set your own specific concentration limits for the harmonised hazard classes (Art. 10(4)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 10, paragraph 4Click opens the article on EUR-Lex.), and a later review cannot overturn them (Art. 15(4)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 15, paragraph 4Click opens the article on EUR-Lex.).

Harmonisation is the normal route for the most serious hazards: respiratory sensitisers, substances that are carcinogenic, mutagenic or toxic to reproduction, endocrine disruptors, and PBT, vPvB, PMT and vPvM substances (Art. 36(1)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 36, paragraph 1Click opens the article on EUR-Lex.). A national authority, or a manufacturer, importer or downstream user, proposes an entry to ECHA (Art. 37(1)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 37, paragraph 1Click opens the article on EUR-Lex., Art. 37(2)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 37, paragraph 2Click opens the article on EUR-Lex.). ECHA’s Committee for Risk Assessment gives an opinion, and the Commission adds the entry to Annex VI by a delegated act (Art. 37(5)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 37, paragraph 5Click opens the article on EUR-Lex.).

Each such act carries its own start date. The latest act amending CLP that the EU Publications Office listed on 5 October 2026, Delegated Regulation (EU) 2025/1222, introduces or updates the harmonised classification of certain substances. It applies from 1 February 2027, and suppliers may follow it before then (its Article 2). Its recital 6 gives the reason for the gap: time to adapt labels and to sell existing stock.

The ECHA classification and labelling inventory

ECHA keeps a database of the classification of every hazardous substance on the EU market: the classification and labelling inventory (Art. 42(1)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 42, paragraph 1Click opens the article on EUR-Lex.). It covers substances registered under REACH, and hazardous substances placed on the market on their own or in a mixture at a level that makes the mixture hazardous (Art. 39Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 39Click opens the article on EUR-Lex.).

• Who notifies. The manufacturer or the importer that places the substance on the market, alone or as a group (Art. 40(1)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 40, paragraph 1Click opens the article on EUR-Lex.). A downstream user and a distributor do not.
• When. Within one month of placing the substance on the market (Art. 40(3)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 40, paragraph 3Click opens the article on EUR-Lex.). Since 1 July 2026, after a review changes the classification, no later than 6 months after that decision (Art. 40(2)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 40, paragraph 2Click opens the article on EUR-Lex., in the wording of Reg. 2024/2865 Art. 1, point (22)Regulation (EU) 2024/2865, amending the CLP Regulation (consolidated text of 23 December 2025)Article 1, point 22Click opens the article on EUR-Lex.).
• What. The notifier, the substance, its classification, its specific concentration limits, M-factors or acute toxicity estimates where they apply, and its label elements (Art. 40(1)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 40, paragraph 1Click opens the article on EUR-Lex.).
• When it is not needed. If the same information was already submitted in a REACH registration, or already notified by that notifier (Art. 40(1)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 40, paragraph 1Click opens the article on EUR-Lex.).
• Who sees it. ECHA publishes the inventory online, free of charge, including the notifier’s name unless it shows that publication would harm its commercial interests (Art. 42(1)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 42, paragraph 1Click opens the article on EUR-Lex.).

An EU importer of a cleaner or a fragrance oil blend that is classified as hazardous therefore notifies the hazardous substances in it, unless that information was already submitted in a REACH registration or already notified by it.

The new hazard classes: endocrine disruptors, PBT and PMT

Delegated Regulation (EU) 2023/707 added four hazard classes to Annex I. They are EU hazard classes, not GHS ones. Each carries a signal word and an EUH hazard statement (Annex I, Tables 3.11.3, 4.2.3, 4.3.1 and 4.4.1 for the label elements). Why none of them carries a pictogram is in CLP hazard pictograms.

The dates are the same for all four:

Each section of Annex I sets these dates under “Application in time”, for example sections 3.11.2.4 and 3.11.3.4 for endocrine disruption for human health.

Essential oils and other plant extracts have their own classification rule

A substance with several constituents, such as an essential oil, is judged on the information about its known constituents as well as on the substance itself (Art. 5(3)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 5, paragraph 3Click opens the article on EUR-Lex.). For the most serious hazard classes, carcinogenicity, mutagenicity, reproductive toxicity and endocrine disruption, CLP goes further. The same holds for the biodegradation, persistence, mobility and bioaccumulation properties used in the aquatic environment, PBT and PMT hazard classes. Each known constituent is assessed, and data on the whole substance that show no effect, or a milder one, do not override the constituents (Art. 5(4)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 5, paragraph 4Click opens the article on EUR-Lex., Art. 5(5)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 5, paragraph 5Click opens the article on EUR-Lex.).

Since 1 July 2026 that stricter rule does not apply to “substances containing more than one constituent which are extracted from plants or plant parts and which are not chemically modified” (Art. 5(6)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 5, paragraph 6Click opens the article on EUR-Lex., applying from the date in Art. 2(2)Regulation (EU) 2024/2865, amending the CLP Regulation (consolidated text of 23 December 2025)Article 2, paragraph 2Click opens the article on EUR-Lex.). Plants include fungi, algae, lichens and yeasts (Art. 5(7)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 5, paragraph 7Click opens the article on EUR-Lex.). The reason given: some constituents, taken alone, show hazards that the plant substance as a whole may not (recital 3 of Regulation (EU) 2024/2865Regulation (EU) 2024/2865, amending the CLP Regulation (consolidated text of 23 December 2025)The whole regulationClick opens the law on the EU Publications Office.). The Commission reports on this derogation by 11 December 2029, possibly with a proposal to change it (Art. 54a(1)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 54a, paragraph 1Click opens the article on EUR-Lex.).

A blend of essential oils, or an oil mixed with a carrier, is a mixture. It is classified under the mixture rules (Art. 6(1)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 6, paragraph 1Click opens the article on EUR-Lex., Art. 9(4)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 9, paragraph 4Click opens the article on EUR-Lex.).

The nine hazard pictograms

A hazard pictogram is a square set on its point: a black symbol on a white background with a red frame (Art. 2(3)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 2, point 3Click opens the article on EUR-Lex.; Annex I, sections 1.2.1.1 and 1.2.1.2). Annex V sets the nine symbols, GHS01 to GHS09, and pairs each with the hazard classes that call for it. The classification decides which pictograms the label carries. The code, symbol and hazards of each, the size and the rules for small packs are in CLP hazard pictograms. The sizes of the label itself are in CLP label requirements.

What the 2024 revision changed, and when

What are the latest updates to the CLP Regulation? They come from Regulation (EU) 2024/2865Regulation (EU) 2024/2865, amending the CLP Regulation (consolidated text of 23 December 2025)The whole regulationClick opens the law on the EU Publications Office., which entered into force on 10 December 2024 (Art. 2(1)Regulation (EU) 2024/2865, amending the CLP Regulation (consolidated text of 23 December 2025)Article 2, paragraph 1Click opens the article on EUR-Lex.). Its changes start on four dates. Regulation (EU) 2025/2439Regulation (EU) 2025/2439, deferring dates of the 2024 CLP revisionThe whole regulationClick opens the law on the EU Publications Office. moved the last group from 2026 and 2027 to 1 January 2028 (its Article 1).

Stock already on the market gets extra time. Products placed on the market before 1 July 2026 under the earlier rules need not meet the new classification and small-pack rules until 1 July 2028 (Art. 61(7)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 61, paragraph 7Click opens the article on EUR-Lex.). Products placed on the market before 1 January 2027 under the earlier product identifier and label format rules need not meet the new ones until 1 January 2029 (Art. 61(8)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 61, paragraph 8Click opens the article on EUR-Lex.). You may use the 2028 label format already (Art. 2(6)Regulation (EU) 2024/2865, amending the CLP Regulation (consolidated text of 23 December 2025)Article 2, paragraph 6Click opens the article on EUR-Lex.).

The label rules, the listing rules and their dates in detail are in CLP label requirements, which also covers what 2025/2439 left unclear for stock placed on the market during 2027.

What happens if you do nothing

What is CLP compliant? A product that has been “classified, labelled, notified and packaged in accordance with this Regulation” (Art. 46(1)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 46, paragraph 1Click opens the article on EUR-Lex.). A substance or mixture that does not comply may not be placed on the market (Art. 4(10)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 4, paragraph 10Click opens the article on EUR-Lex.). Each EU country runs official controls to keep such products off its market, and sets its own penalties, which must be “effective, proportionate and dissuasive” (Art. 46(1)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 46, paragraph 1Click opens the article on EUR-Lex., Art. 47Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 47Click opens the article on EUR-Lex.). What market surveillance and customs can do with a product that fails is set out in CLP label requirements.

What is proposed but not yet law

The Commission has proposed to simplify CLP again. Regulation (EU) 2025/2439Regulation (EU) 2025/2439, deferring dates of the 2024 CLP revisionThe whole regulationClick opens the law on the EU Publications Office. names the reason it deferred the label format, advertisement and online offer rules to 2028: that proposal is meant to balance clear labels for consumers against market barriers and administrative burden (recital 2 of Regulation (EU) 2025/2439Regulation (EU) 2025/2439, deferring dates of the 2024 CLP revisionThe whole regulationClick opens the law on the EU Publications Office.). A proposal is not law. The consolidated CLP text of 1 January 2027, the latest the EU Publications Office held on 5 October 2026, lists no amendment adopted on it. Until one is adopted, the 2028 rules stand as written.

What the law leaves open

• Candles and wax melts. No article of CLP names them, and whether one is an article or a mixture decides whether CLP labels it (Art. 2(9)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 2, point 9Click opens the article on EUR-Lex., Art. 4(8)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 4, paragraph 8Click opens the article on EUR-Lex.). The reasoning and the safe course are in CLP label requirements.
• The EU supplier for a parcel sent from outside the EU to a consumer. Art. 4(11)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 4, paragraph 11Click opens the article on EUR-Lex. requires a supplier established in the EU on the label. Every CLP role is an EU business, and a consumer buying for personal use is none of them (Art. 2(17)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 2, point 17Click opens the article on EUR-Lex., Art. 2(19)Regulation (EC) No 1272/2008, CLP (classification, labelling and packaging), consolidated text of 1 January 2027Article 2, point 19Click opens the article on EUR-Lex.). No article names who fills the role on this route. Meanwhile, sell a substance or mixture into the EU through an EU business that is named on the label and takes on the CLP duties.