Hazard Communication - The Label
The label is the main tool for communicating information on hazardous substances and mixtures throughout the supply chain. Together with the safety data sheet, the label communicates hazard information for a substance or mixture to the user. This enables the user to best protect themselves during use. The responsibility for labelling lies with the entity who places the hazardous substance or mixture on the EU market.
Labelling
A hazardous substance or mixture contained in packaging should be labelled according to CLP before it is placed on the market. Suppliers (manufacturers, importers, downstream users and distributors) must communicate the hazards to other actors in the supply chain, including consumers. Distributors and downstream users can use the classification and labelling from their supplier, provided that the classification is derived using CLP, and they do not change the composition of the substance or mixture before placing it on the market.
The CLP Label
A label must contain the following:
- name, address and telephone number of the EU supplier*
- product identifiers e.g. chemical name and CAS/EC no. for a substance/trade name of a mixture as well as chemical name(s) of all substances responsible for classification of mixture (excluding skin and eye irritants)
- relevant hazard pictogram(s)
- relevant signal word: either Warning or Danger
- hazard statement(s)
- appropriate precautionary statements
- nominal quantity (for supply to general public)
- unique formula identifier (UFI), if the product is a hazardous mixture (health and physical hazards)
- obligatory supplemental information
Non-obligatory supplemental labelling information is not part of the CLP labelling requirements, for example, instructions for use. Such information must not distract from, nor contradict, the obligatory label elements and statements; for example, ‘non-toxic’ or ‘non-polluting’ must not be used.
*From 1 July 2026, Article 4(11) of the revised CLP Regulation (Regulation (EU) 2024/2865)requires a supplier established in the EU to be in place for any substance or mixture in the scope of CLP that is placed on the EU market.This supplier,in the course of an industrial or professional activity, i.e., not a consumer, must ensure that the substance or the mixture meets the CLP requirements when it is being placed on the market, including via distance sales, such as via online marketplaces.
The label must:
- be firmly attached to one or more surfaces of the packaging immediately containing the substance or mixture and must be readable horizontally when the package is set down normally
- be visible and readable in English
- have all hazard pictograms, signal word, hazard and precautionary statements together
- have all hazard and precautionary statements of the same language grouped together, where there is more than one language used
- ensure that the hazard pictogram stands out clearly (black print on white background surrounded by red frame being at least one fifteenth and at least 1 cm2 of the label)
- have the dimensions as set out in Annex I of CLP
Labels can be presented in the form of fold-out labels.
The provision of CLP relating to minimum font size was amended by the revised CLP Regulation (Regulation (EU) 2024/2865); however, it is the subject of simplification as part of the Omnibus VI Regulation, which is expected to be published in the Official Journal by the end of 2026. The information provided here is based on the currently applicable CLP Regulation.
Derogations from Labelling
Derogations from labelling are permitted where packages are of such a shape or so small that the necessary labelling information does not fit on the label. In such cases the label elements set out in Article 17 may be provided in accordance with section 1.5.1 of Annex I of CLP. In such cases, and where applicable, the label elements may be provided either on:
- tie-on tags; or
- outer packaging
A derogation also applies for chemicals for supply for Research and Development or Quality Control analysis, where the contents of the inner package do not exceed 10ml and where the outer package is labelled accordingly. Derogations from labelling requirements are also permitted in special cases including transportable gas cylinders, gas containers intended for propane, butane or liquefied petroleum gas, certain aerosols, certain mixtures containing elastomers and explosives, as well as in the case of soluble packaging.
Substances or mixtures that are not placed on the market, such as decanted chemicals, do not come under the scope of the CLP Regulation. It is important, however, that a risk-based approach to potential hazards and the requirement to label ‘in-house’ containers are considered under the remit of the Chemical Agent Regulations and the Work Place Signs Regulations
Updating labels
Note: This provision of CLP was amended by the revised CLP Regulation (Regulation (EU) 2024/2865), it is the subject of simplification as part of the Omnibus VI Regulation, which is expected to be published in the Official Journal by the end of 2026. The information provided below is based on the currently applicable CLP Regulation.
If the classification and labelling of a substance or a mixture changes (based on an evaluation in accordance with Article 15(4)) such that a more severe classification applies, or new supplemental label elements are required in accordance with Article 25, the supplier must update the label without undue delay once they obtain, or are made aware of, the results of the new evaluation. This obligation applies individually to each supplier in the supply chain.
Where labelling changes other than those described above are required (e.g. where the revised classification will be less severe or the contact details of the supplier have changed), the supplier must update the label without undue delay, and in any case, within 18 months.
Where new or updated harmonised classification and labelling arises from a Commission Delegated Act, the act provides for the mandatory application date.
Digital labelling
In addition to a physical label, the label elements referred to in Article 17 can also be provided in a digital form, i.e. “digital label”. The label elements set out in section 1.6 of Annex I can be provided on a digital label only. Where the information is provided through a digital label, the following requirements apply:
- all label elements referred to in Article 17(1) must be provided together in one place and separately from other information
- the information on the digital label must be searchable
- the information on the digital label must be accessible to all users in the EU and must remain accessible for a period of at least 10 years or for a longer period where required by other EU legislation
- the digital label must be accessible free of charge, without the need to register or to download or install applications, or to provide a password
- the information on the digital label must be presented in a way that also addresses the needs of vulnerable groups and supports, as relevant, the necessary adaptations to facilitate access to the information by those groups
- the information on the digital label must be accessible with no more than two clicks
- the digital label must be accessible through digital technologies widely used, and compatible with all major operating systems and browsers
- where the information on the digital label is accessible in more than one language, the choice of language must not be conditioned by the geographical location from which that information is accessed
Labels for Supply and Transport
For hazardous substances and mixtures that are transported by road, every inner and intermediate layer of packaging must be labelled according to CLP, and outer packaging must be labelled according to ADR. Outer packaging may also carry CLP labelling; however this is not a requirement unless hazardous substances are provided in a single package (e.g. a drum). Single packages must carry both the CLP and the ADR label elements. ADR labels or marks take precedence over CLP pictograms on a combined supply and transport label for the same hazard. Please consult the ADR section of our website.
Labelling Guidance:
HSA: Hazard, Labelling & Packaging according to the CLP Regulation
ECHA: Guidance on Labelling and Packaging