Classification, Labelling and Packaging (CLP Regulation)

Regulation (EC) No 1272/2008 on Classification, Labelling and Packaging of Substances and Mixtures

6 New Hazard Classes. Revised Labelling Rules Live in 2026. Are Your Supplier SDSs and Classifications Current?

CLP compliance requires accurate hazard classification, compliant labelling, and Poison Centre notifications for every substance and mixture on the EU market. Six new hazard classes are now mandatory. Regulation (EU) 2024/2865 introduces revised labelling, digital label provisions, and expanded distributor obligations—most effective July 2026.

Certivo automates CLP evidence collection from supplier SDS validation to audit-ready hazard documentation.

Key Information

• New hazard classes now mandatory under CLP: ED, PBT, vPvB, PMT, vPvM
• Most Regulation 2024/2865 provisions become mandatory: July 2026
• Substances with harmonised classification in Annex VI: 4,000+

Regulation Overview

• Jurisdiction: European Union / European Economic Area (GB CLP applies separately post-Brexit)
• Regulatory Body: European Chemicals Agency (ECHA)
• Regulation Number: EC 1272/2008 (amended by EU 2023/707 and EU 2024/2865)
• Effective Date: January 20, 2009 (new hazard classes from May 2025; revised CLP from July 2026)
• Official Source: ECHA CLP Legislation
• Key Threshold: Classification triggers apply at specific concentration limits per hazard class

What is the CLP Regulation?

The CLP Regulation is the EU's implementation of the UN Globally Harmonised System (GHS) for classifying and communicating chemical hazards. For supply chain teams, the primary obligation is ensuring that every substance and mixture placed on the EU market carries the correct hazard classifications, compliant labels with GHS pictograms and hazard statements, and up-to-date Safety Data Sheets reflecting current classification data.

CLP now includes six new hazard classes—endocrine disruptors for human health and environment, PBT, vPvB, PMT, and vPvM—mandatory for new substances since May 2025 with existing substances required to comply by November 2026. Companies must also submit Poison Centre notifications via ECHA's portal under Annex VIII and maintain C&L Inventory notifications within one month of placing substances on the market.

Key Components / Sub-Frameworks

• Obligation: Mandatory classification for listed substances; self-classification for others
• Annex VI: Table of harmonised classification and labelling
• Obligation: Harmonised submission of mixture composition to national Poison Centres via ECHA portal
• Annex VIII: Poison Centre notification requirements
• Obligation: Mandatory for new substances from May 2025; existing substances by Nov 2026; mixtures by May 2028
• Delegated Reg. 2023/707: Six new hazard classes (ED, PBT/vPvB, PMT/vPvM)

Key Compliance Requirements

Who Must Comply

• EU/EEA manufacturers of chemical substances and mixtures
• Importers placing substances or mixtures on the EU market
• Downstream users who further process or reformulate mixtures
• Non-EU companies selling chemicals to EU customers via online channels
• Companies submitting Poison Centre notifications under Annex VIII
• Distributors selling, rebranding, or relabelling hazardous products in the EU

Key Thresholds

• Specific concentration limits (SCLs): Trigger classification of mixtures based on hazardous ingredient percentages
• Generic concentration limits (GCLs): Default thresholds when no SCL is set—vary by hazard class
• 1 month: Deadline for C&L Inventory notification after placing substance on market
• UFI (Unique Formula Identifier): Required on labels of hazardous mixtures notified to Poison Centres

Core Obligations

1. Self-Classification: Classify substances/mixtures against all applicable hazard classes including new ED/PBT/PMT classes
   • DEADLINE: Ongoing; new hazard classes mandatory for new substances from May 2025
2. Labelling: Apply correct GHS pictograms, signal words, hazard/precautionary statements, UFI code
   • DEADLINE: At time of placing on market; revised format rules from July 2026
3. Poison Centre Notification: Submit composition and hazard data for hazardous mixtures via ECHA portal (Annex VIII)
   • DEADLINE: Required since January 2024; harmonised format since January 2025
4. C&L Inventory Notification: Notify ECHA of classification and labelling for every substance placed on market
   • DEADLINE: Within 1 month of placing on market
5. SDS Update: Update Safety Data Sheets to reflect current CLP classification
   • DEADLINE: Ongoing; within 6 months of classification change

Key Statistics

• 4,000+ Harmonised classifications tracked with automatic Annex VI sync
• 99.2% Classification extraction accuracy from supplier SDSs
• 95% Supplier response rate with CORA-powered campaigns

Frequently Asked Questions

1. Which companies must comply with the CLP Regulation?
   The CLP Regulation applies to all manufacturers, importers, downstream users, and distributors placing chemical substances or mixtures on the EU/EEA market.
2. What are the penalties for CLP non-compliance?
   Enforcement penalties vary by jurisdiction and may include product withdrawal, import bans, fines, and criminal liability.
3. How does Certivo handle the six new CLP hazard classes?
   Certivo tracks compliance against the deadlines for existing substances and mixtures, validating classification data.
4. What SDS formats does Certivo accept?
   Certivo accepts multiple formats including PDF, XML, IUCLID, and Excel.
5. How does CLP compliance relate to REACH?
   CLP governs classification while REACH governs registration, evaluation, and restriction of substances.