EU regulation
CLP Regulation: classification, labelling and packaging
Overview
Short answer
The CLP Regulation, (EC) No 1272/2008, governs classification, labelling and packaging of chemical substances and mixtures. Start with the product’s identity and hazardous properties. A statement of REACH compliance does not by itself establish that the CLP label is correct. Articles 1 and 4.
Legal status
Law in force with phased application
CLP is law in force. This overview was checked on 11 October 2026 against the consolidation of 1 July 2026 and the named amending acts. New hazard classes and later labelling rules have different application dates. Substance-specific entries require checking in the product assessment.
Part 1
Which products are covered?
CLP primarily concerns substances and mixtures such as adhesives, cleaning agents and paint. Explosive articles have specific rules. Ordinary finished articles do not automatically have the same labelling requirements as a chemical mixture. Article 1 also contains exclusions, including certain finished products intended for the final user. Scope the product before assessing its label. Article 1.
Part 2
Responsibility along the supply chain
Manufacturers, importers and downstream users have classification responsibilities according to their role. Distributors may use an earlier classification under specified conditions. A harmonised classification must be followed for the hazards covered by its entry; other relevant hazards still need assessment. The revised regulation also requires an EU-established supplier identified on the label. Article 4.
Part 3
From assessment to label
Identify the product, supplier and relevant hazard statements, precautionary statements, signal words and pictograms. Check the physical packaging, not only a supplier’s PDF. Read the conditions for any small-packaging exemptions. Among other requirements, packaging must prevent the contents escaping. An attractive label cannot compensate for an incorrect classification. Articles 17 and 35.
Part 4
Separate the amendment timetables
Regulation (EU) 2023/707 introduces new hazard classes with separate dates for substances and mixtures and transitions for products already placed on the market. For new mixtures, those requirements apply from 1 May 2026. Regulation (EU) 2025/2439 postpones certain other revised labelling and sales requirements to 1 January 2028. This is not a general postponement of CLP. Annex application provisions. Article 1.
Part 5
Evidence that can be followed
Collect the formulation or composition, substance identities, concentrations, relevant supplier information and the reasoning behind the assessment. Link the label artwork to the same version. As a working method, document missing information and who will assess it. A safety data sheet is useful evidence, but check that it concerns the right product rather than an earlier formulation.
Part 6
When something changes
Use a changed formulation, new hazard information or changed substance classification to trigger another review. Follow the effect through to labels, stock, customer information and affected markets. A simple change record can identify what changed, which products are affected, which legal version was used and when action is due. Distinguish proposed changes from adopted legislation.
Checklist
Key takeaways
- Establish whether you supply a substance, mixture or article.
- Classification, label and packaging need to agree.
- New hazard classes and revised labelling have different timetables.
- Keep evidence for the exact composition and version.
Questions and answers
Frequently asked questions
Does CLP apply to all articles?
No. Distinguish ordinary articles from substances, mixtures and the specific explosive articles covered.
Is a REACH declaration sufficient?
No. CLP has its own classification and hazard communication requirements.
Have all new rules moved to 2028?
No. The postponement in 2025/2439 concerns specified amendments, not all of CLP.
Can we copy the supplier’s label?
Only after checking role, product, composition and market. A similar trade name is insufficient.
How Verca helps
How Verca can support the process
Verca connects product data and document versions, making the assessment evidence easier to follow. Chemical classification and correct labelling still require responsible expertise. Platform.