CLP Regulation

What does the CLP Regulation regulate?

The CLP Regulation defines hazard classes and categories (physical hazards, such as explosives, flammables, oxidizers, gases under pressure, and corrosives to metals; health hazards, such as acute toxicity, corrosion and skin and eye irritation, sensitization, mutagenicity, carcinogenicity, reproductive toxicity, specific target organ toxicity, and aspiration hazard; and hazards to the aquatic environment and the ozone layer), the criteria for assigning them based on available data, and the communication elements associated with each. Classification can be harmonized, when it is included in Annex VI of the Regulation and is mandatory throughout the Union, or carried out by the supplier according to the Regulation’s criteria (self-classification).

The label must include the supplier’s identity, product identification, hazard pictograms (nine symbols in a red diamond), the signal word (Danger or Warning), hazard statements (H phrases), precautionary statements (P phrases), and, where applicable, supplementary information (EUH phrases). Packaging must be secure, with child-resistant closures and tactile warnings where appropriate. Suppliers report classifications to the ECHA Classification and Labelling Inventory and communicate information on hazardous mixtures to poison control centers using the unique formula identifier (UFI).

Delegated Regulation (EU) 2023/707 introduced new hazard classes for endocrine disruptors affecting human health and the environment, persistent, bioaccumulative and toxic substances (PBT) and very persistent and very bioaccumulative substances (vPvB), and persistent, mobile and toxic substances (PMT) and very persistent and very mobile substances (vPvM). Regulation (EU) 2024/2865, published in November 2024, revised the CLP to improve label readability (format, minimum font size and contrast), regulate digital labelling as a complement, online and distance selling, refillable packaging and advertising, and set staggered implementation deadlines between 2026 and 2029, with the possibility of voluntary application from its entry into force.

CLP in occupational risk prevention

• Hazard identification. The CLP classification of each product, visible on the label and in section 2 of the safety data sheet, is the starting point for the inventory of chemical agents and the risk assessment of Royal Decree 374/2001.
• Safety data sheets. The REACH Regulation requires the supplier to provide a 16-section safety data sheet for hazardous substances and mixtures, with information on hazards, composition, first aid measures, handling, exposure controls and limit values, properties and disposal; the employer must make it available to workers.
• Derived regulations. Classification as carcinogenic, mutagenic or toxic to reproduction in categories 1A or 1B activates the application of Royal Decree 665/1997; classification as flammable or explosive, that of Royal Decree 681/2003 on explosive atmospheres; and classification as sensitizing or corrosive guides the selection of PPE and health surveillance.
• Labeling in the workplace. Containers and pipes with hazardous substances or mixtures must be labelled or marked in accordance with Royal Decree 485/1997, which refers to the CLP pictograms; transfers to non-original containers require relabeling.
• Information and training. Royal Decree 374/2001 requires that workers be informed and trained on the dangers of products, including the meaning of pictograms and H and P phrases.
• Substitution. The classification allows for the comparison of products and the application of the principle of substitution with less dangerous ones, which is a priority in the control hierarchy.
• Purchasing and access control. Checking the label and safety data sheet at receiving prevents the entry of products without information or with a classification that requires unforeseen measures.
• Emergencies. The label and data sheet information guides procedures in case of spills, fires and accidental exposures, and poison control centers have the reported composition.

Obligations and actors

• Manufacturers and importers. Classify, label and package in accordance with CLP, notify the ECHA inventory and, for hazardous mixtures, the poison control centers.
• Intermediary users and distributors. Apply the supplier’s classification or classify when they modify the product, maintain the labeling and transmit the information in the supply chain; Regulation (EU) 2024/2865 reinforces the obligations of distributors and distance sellers.
• User companies. No obligation to classify, but with the duty to use CLP information in risk assessment, internal labeling, training and product management.
• ECHA. Manages the classification and labelling inventory, harmonised classification proposals and technical guidance.
• National authorities. The Ministry of Health and the autonomous communities monitor the market, and the Labor and Social Security Inspectorate controls compliance in the workplace; the INSST publishes tools such as RISKQUIM for the identification and classification of hazards.
• Globally Harmonized System. The CLP implements the United Nations GHS, which facilitates consistency with the classification systems of other countries and with the transport of dangerous goods.

Organizational application: how to use CLP in preventive management

1. Inventory all chemicals present with their CLP classification, pictograms and H phrases, and obtain and file the updated safety data sheets.
2. Use the classification to prioritize risk assessment and apply the resulting regulations (carcinogens, explosive atmospheres, PPE, health surveillance).
3. Upon receiving products, verify the label and data sheet conformity, and reject those that lack information.
4. Label internal packaging and transfers and mark containers and pipes in accordance with Royal Decree 485/1997.
5. Train workers on the meaning of pictograms, H and P phrases, and the use of safety data sheets.
6. Apply the principle of substitution by comparing classifications and choosing less hazardous products where feasible.
7. Follow CLP updates (new hazard classes, labelling rules and deadlines of Regulation (EU) 2024/2865) and review inventory and assessments when a product’s classification changes.

Preventive management software allows you to maintain the inventory of chemical products with their classification, pictograms and safety data sheets, link them to jobs and risk assessments, generate internal labels and alert about outdated data sheets or changes in classification.

Limits and common mistakes

1. Working with products without CLP compliant labeling or without safety data sheets, or with outdated data sheets.
2. Transferring products to containers without relabeling, especially to food or beverage containers.
3. Ignoring the classification as carcinogenic, mutagenic or toxic to reproduction and not applying Royal Decree 665/1997.
4. Confusing the pictogram or warning word with a risk assessment: the label informs of the hazard, not the actual exposure.
5. Do not train workers in reading labels and cards or facilitate their access.
6. Ignorance of the new hazard classes and labelling deadlines of Regulation (EU) 2024/2865.

The text of the CLP Regulation, its annexes and the ECHA guidelines detail the classification and labelling criteria; this sheet is for informational purposes.

Regulatory and reference framework

• Regulation (EC) No 1272/2008 (CLP) . Classification, labelling and packaging of substances and mixtures.
• Regulation (EU) 2024/2865 . Amendment to the CLP Regulation: labelling, format, online sales and application deadlines.
• Regulation (EC) No 1907/2006 (REACH) . Registration, Evaluation, Authorisation and Restriction of Chemicals; Safety Data Sheets.
• Royal Decree 374/2001, of April 6. Protection against risks related to chemical agents during work; use of information from labels and data sheets.
• Royal Decree 485/1997, of April 14. Safety and health signage; labelling of containers and pipes in accordance with CLP pictograms.
• European Chemicals Agency (ECHA): Understanding CLP . Official information on the regulation, inventory and guidelines.

Delegated Regulation (EU) 2023/707 introduced the hazard classes for endocrine disruptors, PBT, vPmB, PMT and vPmM; the INSST publishes the RISKQUIM tool for the identification and classification of chemical hazards.