Labelling

Suppliers must label substances or mixtures in accordance with the requirements of the CLP Regulation before placing them on the market. The purpose of labelling is to inform anyone working with a substance/mixture of the hazards it poses. In addition, in the case of the supply of hazardous substances and mixtures, the supplier is obliged to provide its customers - industry representatives involved in the supply chain - with a Safety Data Sheet (SDS).

CLP labelling

If you are a manufacturer, importer, downstream user (including a formulator of a mixture) or distributor (including a retailer), you must label all substances or mixtures that are required to be labelled and contained in the packaging before they can be placed on the market (Article 4(4) of the CLP Regulation). This requirement also applies to manufacturers and importers of products that qualify as explosive in accordance with the criteria in Part 2 of Annex I to the CLP Regulation.

The substance or mixture in the packaging must be labelled in accordance with the rules of the CLP Regulation:

• if the substance or mixture is classified as hazardous; or
• if one or more substances in the composition of the mixture are classified as hazardous in concentrations above those given in Part 2 of the CLP Regulation, even if the mixture is not classified as hazardous. In this case, the additional labelling referred to in Part 2 of Annex I to the CLP Regulation must be used (Article 25(6) of the CLP Regulation); and
• if the product is explosive as described in Part 2 of Annex I to CLP.

Label

The label shall be written in the official language of the Member State in which the substance or mixture is placed on the market, unless the Member State concerned provides otherwise. Labels for substances or mixtures supplied in Lithuania must be in Lithuanian.

Suppliers of a substance or mixture may use more languages on the label than those required by the Member State, provided that the same information is provided in all languages.

The CLP Regulation provides for the following information to be included on the label:

• the name, address and telephone number of the supplier(s) of the substance or mixture ;
• the nominal quantity of the substance or mixture in the packages made available to the general public (unless this quantity is indicated elsewhere on the package);
• identification of the product;
• where appropriate, hazard pictograms, signal words, hazard statements, precautionary statements and additional information which may be required by other legislation, such as legislation on volatile organic compounds or detergents.

Since elements of the classification and labelling of a substance or a mixture, such as signal words, hazard pictograms, hazard statements and precautionary statements, may be repeated or redundant, rules for the application of the principle of relevance have been developed to avoid such situations.

In addition, the CLP Regulation also specifies the size of labels and pictograms, the additional information to be provided, provides for exceptions for small packages and describes how the CLP Regulation relates to transport labelling requirements.

A hazard pictogram is a graphic representation of a label consisting of a warning symbol and special colours designed to convey information about the potential hazards of a specific substance or mixture to our health or the environment. As provided for in Annex V of the CLP Regulation, hazard pictograms shall include a black symbol on a white background with a red border wide enough to be clearly visible. Hazard pictograms shall be in the shape of a rotated square. Each hazard pictogram shall be at least one fifteenth of the area of the harmonised label, but not less than 1 cm ². Free icons for printing can be found and downloaded from here. 

Table : Minimum outline of labels and pictograms

Specific labelling and packaging situations

If the substance and mixture are in small packages (usually up to 125 ml) or are difficult to label for other reasons, the CLP Regulation provides for exemptions from the usual labelling requirements. These exemptions provide that where a substance or mixture is classified for a hazard listed in section 1.5 of Annex I to the CLP Regulation, the supplier may omit the following labelling elements: hazard statements and/or precautionary statements or pictograms normally required by CLP.

If substances or mixtures/preparations are supplied to the public with a specific hazard or if the packaging material contains methanol or dichloromethane, the containers shall be closed in such a way that they cannot be opened by children (CRF) and/or the hazard warning shall be tactile (TW). CRF or TW are essential for different types of hazards. Examples are given in the following table.

Table : Hazard classifications resulting in the application of CLP provisions on child-resistant fastenings and/or tactile hazard statements

Finally, the CLP Regulation introduces new rules for situations where the packaging of hazardous substances or mixtures consists of outer, inner andintermediate packaging.

Generally, when the outer packaging labelling is also subject to the regulations on the transport of dangerous goods and CLP regulations, CLP labelling is not required - only the labelling or marking required by the regulations on the transport of dangerous goods is sufficient. Accordingly, where the hazard pictogram required by CLP refers to the same hazard as the mark required by the rules on the transport of dangerous goods, the outer packaging may not bear the pictogram required by CLP.

ECHA guidance documents

• Introductory guidance to the CLP Regulation.
• Guidelines on labelling and packaging in accordance with Regulation (EC) No 1272/2008.