CLP Labelling Regulations: A Complete UK Guide
If your business manufactures, imports, or supplies chemicals in Great Britain, CLP labelling is a legal requirement you cannot afford to get wrong. The Classification, Labelling and Packaging (CLP) Regulation governs how hazardous substances and mixtures must be identified, labelled, and packaged before they reach the market – whether that market is industrial, professional, or consumer.
This guide explains the UK CLP requirements in practical terms: what must appear on your labels, which pictograms apply, how to handle hazard and precautionary statements, and what happens if you fall short of compliance. Whether you produce cleaning products, paints, adhesives, agrochemicals, or industrial solvents, the rules covered here apply to you.
Contents
- What Is CLP?
- UK CLP Post-Brexit: GB CLP vs EU CLP
- Who Needs CLP Labels?
- What Must Appear on a CLP Label?
- The Nine GHS Hazard Pictograms
- Signal Words: Danger and Warning
- Hazard Statements (H-Codes)
- Precautionary Statements (P-Codes)
- Label Size and Pictogram Size Requirements
- Small Packaging and Fold-Out Labels
- How to Classify Your Substances and Mixtures
- Products Exempt from CLP
- CLP and UK REACH: How They Work Together
- Safety Data Sheets (SDS)
- Enforcement and Penalties
- Common CLP Labelling Mistakes
- Practical Steps to CLP Compliance
- Recent EU CLP Changes (2024) and UK Impact
- Getting Your CLP Labels Right
What Is CLP?
CLP stands for Classification, Labelling and Packaging. It is the regulation that requires businesses to assess the hazards of chemical substances and mixtures, classify them according to standardised criteria, label them with the correct warnings, and package them safely before placing them on the market.
The CLP system is based on the United Nations’ Globally Harmonised System of Classification and Labelling of Chemicals (GHS). The purpose of GHS is to create a single, internationally recognised framework for communicating chemical hazards. Before GHS, different countries used different symbols, terminology, and classification criteria – meaning a product labelled as harmful in one country might not carry the same warning in another. GHS replaced the older orange-and-black hazard symbols (used under the previous CHIP regulations in the UK) with the now-familiar red-bordered diamond pictograms.
The EU adopted GHS through Regulation (EC) No 1272/2008 – the CLP Regulation – which came into force in January 2009. It applied to all substances from December 2010 and to all mixtures from June 2015, replacing the earlier Dangerous Substances Directive (DSD) and Dangerous Preparations Directive (DPD).
UK CLP Post-Brexit: GB CLP vs EU CLP
Since 1 January 2021, the UK has operated its own version of CLP. The EU CLP Regulation was retained in GB law and amended to function independently, creating what is formally known as the GB CLP Regulation. The core duties to classify, label, and package hazardous chemicals remain the same, but several important changes apply.
The Health and Safety Executive (HSE) is now the GB CLP Agency, taking over functions previously carried out by the European Chemicals Agency (ECHA). This includes maintaining the GB Mandatory Classification and Labelling (MCL) list – the UK equivalent of the EU’s Annex VI harmonised classifications. All harmonised classifications that were in force under EU CLP on 31 December 2020 have been retained in UK law.
However, GB CLP and EU CLP are now updated independently. The EU has continued to add new harmonised classifications through Adaptations to Technical Progress (ATPs), and in 2024 published a major revision to the CLP Regulation itself. The UK has taken its own approach – the HSE published version 4 of the GB MCL list in 2024, adding new substances and updating existing classifications through its own regulatory process.
There is a crucial geographic distinction to understand. GB CLP applies in England, Scotland, and Wales. In Northern Ireland, EU CLP continues to apply under the Windsor Framework. If your business supplies chemicals to both GB and Northern Ireland markets, you may need to comply with both regulatory frameworks. The practical differences are currently small, but they are expected to grow over time as the two systems diverge.
One notable difference already: the EU now requires a Unique Formula Identifier (UFI) on labels for mixtures classified as hazardous, linked to poison centre notifications. This requirement does not apply in GB, though it does apply in Northern Ireland.
Who Needs CLP Labels?
CLP applies to any business that places hazardous substances or mixtures on the GB market. The regulation applies regardless of the volume supplied – there is no minimum quantity threshold. The main duty holders are:
Manufacturers who produce chemical substances or formulate mixtures in Great Britain are responsible for classifying their products and ensuring correct labelling and packaging before supply.
Importers who bring substances or mixtures into GB from outside the UK (including from the EU since Brexit) take on the same responsibilities as manufacturers. If you import a product that was correctly labelled for the EU market, you must still verify that it meets GB CLP requirements.
Downstream users who use chemicals in their own formulations or processes may also have classification and labelling obligations, particularly if they create new mixtures or use substances in ways not covered by the original supplier’s classification.
Distributors who store and supply chemicals without altering them must ensure that products they place on the market are correctly classified, labelled, and packaged. While they typically rely on the manufacturer’s or importer’s classification, they share responsibility for ensuring compliance at the point of supply.
The range of products covered is broad. Common examples include paints and coatings, cleaning products, adhesives, solvents, fuel additives, aerosol products, pesticides and herbicides, laboratory chemicals, and industrial raw materials. If your product is classified as hazardous – whether for physical, health, or environmental reasons – it needs a CLP-compliant label. At PID Labelling, we work with businesses across all these sectors to produce chemical labels that meet every requirement of the GB CLP Regulation.
What Must Appear on a CLP Label?
A CLP-compliant label for a hazardous substance or mixture must include all of the following elements, as specified in Article 17 of the CLP Regulation:
Supplier identification – the name, address, and telephone number of the manufacturer, importer, or other responsible supplier based in Great Britain.
Product identifiers – for substances, this means the chemical name and identification number (typically EC or CAS number). For mixtures, this is the trade name or designation plus the identity of specific substances that contribute to the classification.
Hazard pictograms – the red-bordered diamond symbols indicating the type of hazard. The specific pictograms required are determined by the product’s classification.
Signal word – either “Danger” (for more severe hazards) or “Warning” (for less severe hazards). Only one signal word appears on a label.
Hazard statements (H-codes) – standardised phrases describing the nature and degree of the hazard, such as “Highly flammable liquid and vapour” or “Causes serious eye damage”.
Precautionary statements (P-codes) – standardised phrases describing recommended measures to minimise or prevent adverse effects, covering prevention, response, storage, and disposal.
Supplemental information – any additional hazard information required under Annex II of the CLP Regulation, plus the nominal quantity of the product in the package where it is supplied to the general public.
The label must be firmly affixed to the packaging surface, positioned so it can be read horizontally when the package is set down normally. All text must be clear, indelible, and of a size and spacing that makes it easy to read. The colour and presentation must allow the hazard pictograms to stand out clearly against the label background.
The Nine GHS Hazard Pictograms
CLP uses nine standardised hazard pictograms, each displayed as a black symbol on a white background within a red diamond-shaped border. These replaced the older orange-and-black CHIP symbols. Each pictogram is identified by a GHS code number.
GHS01 – Exploding Bomb
Used for explosive substances, self-reactive substances, and organic peroxides that may explode or self-decompose under certain conditions such as heat, friction, or impact. Products carrying this pictogram include certain industrial chemicals, fireworks components, and explosive articles.
GHS02 – Flame
Used for flammable gases, aerosols, liquids, and solids, as well as self-reactive substances, pyrophoric materials, self-heating substances, and substances that emit flammable gases on contact with water. This is one of the most commonly seen pictograms, appearing on products from paint thinners to aerosol sprays.
GHS03 – Flame Over Circle
Used for oxidising gases, liquids, and solids – substances that may cause or intensify fire by providing oxygen. Common examples include hydrogen peroxide solutions and certain bleaching agents.
GHS04 – Gas Cylinder
Used for gases under pressure, including compressed gases, liquefied gases, refrigerated liquefied gases, and dissolved gases. The pictogram warns that containers may explode if heated.
GHS05 – Corrosion
Used for substances corrosive to metals, or causing severe skin burns and serious eye damage. The symbol depicts a substance corroding both a surface and a hand. Common products include strong acids, alkalis, and concentrated cleaning products.
GHS06 – Skull and Crossbones
Used for acutely toxic substances that can cause death or serious harm even in small quantities through ingestion, skin contact, or inhalation. This pictogram is reserved for the most dangerous acute toxicity categories (Categories 1, 2, and 3).
GHS07 – Exclamation Mark
Used for less severe health hazards including skin and eye irritation, skin sensitisation, acute toxicity (Category 4), specific target organ toxicity from single exposure, and respiratory tract irritation. This is the most frequently used health hazard pictogram.
GHS08 – Health Hazard
Used for more serious chronic health hazards including respiratory sensitisation, carcinogenicity, germ cell mutagenicity, reproductive toxicity, specific target organ toxicity (repeated exposure), and aspiration hazard. The silhouette symbol indicates damage to internal organs.
GHS09 – Environment
Used for substances hazardous to the aquatic environment, both acute and chronic. The symbol shows a dead tree and dead fish. It applies to pesticides, certain solvents, and many industrial chemicals.
There are important precedence rules that reduce the number of pictograms on a label when multiple hazards apply. If GHS01 (Exploding Bomb) is required, GHS02 (Flame) and GHS03 (Flame Over Circle) become optional. If GHS06 (Skull and Crossbones) is required, GHS07 (Exclamation Mark) must not appear. If GHS05 (Corrosion) is required, GHS07 does not appear for skin or eye irritation. These rules prevent label overload while ensuring the most severe hazards are always communicated.
Signal Words: Danger and Warning
CLP uses two signal words to indicate the relative severity of a hazard. “Danger” is used for the more severe hazard categories, while “Warning” is used for less severe categories. Only one signal word may appear on a label – if a product is classified for multiple hazards and both signal words would apply, “Danger” takes precedence and “Warning” is not shown.
Some hazard categories are so low in severity that no signal word is required at all. For example, Chronic Aquatic Hazard Categories 3 and 4 carry no signal word.
Hazard Statements (H-Codes)
Hazard statements are standardised phrases that describe the nature and degree of hazard posed by a substance or mixture. Each statement has a unique H-code identifier, but the full written statement – not just the code – must appear on the label.
H-codes are organised into three series based on hazard type. H2xx codes cover physical hazards (e.g. H220: Extremely flammable gas; H225: Highly flammable liquid and vapour; H271: May cause fire or explosion; strong oxidiser). H3xx codes cover health hazards (e.g. H301: Toxic if swallowed; H315: Causes skin irritation; H350: May cause cancer; H361: Suspected of damaging fertility or the unborn child). H4xx codes cover environmental hazards (e.g. H400: Very toxic to aquatic life; H410: Very toxic to aquatic life with long lasting effects).
GB CLP also retains certain EUH statements – supplemental hazard information that originated in EU-specific provisions and was not part of the original GHS framework. These include statements like EUH001 (Explosive when dry), EUH029 (Contact with water liberates toxic gas), and EUH066 (Repeated exposure may cause skin dryness or cracking). These must appear where applicable, even though they do not have GHS equivalents.
Every hazard statement relevant to the product’s classification must appear on the label. You cannot substitute a code number for the full written statement.
Precautionary Statements (P-Codes)
Precautionary statements are standardised phrases describing measures to minimise or prevent adverse effects from exposure to or improper handling of a hazardous product. They are identified by P-codes and fall into four categories.
P1xx – Prevention statements describe measures to avoid exposure (e.g. P210: Keep away from heat, hot surfaces, sparks, open flames and other ignition sources. No smoking; P261: Avoid breathing dust/fume/gas/mist/vapours/spray).
P2xx/P3xx – Response statements describe measures if exposure or adverse effects occur (e.g. P301+P310: IF SWALLOWED: Immediately call a POISON CENTRE or doctor; P305+P351+P338: IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing).
P4xx – Storage statements describe safe storage conditions (e.g. P403: Store in a well-ventilated place; P405: Store locked up).
P5xx – Disposal statements describe proper disposal methods (e.g. P501: Dispose of contents/container in accordance with local/regional/national regulations).
As a general rule, no more than six precautionary statements should appear on a label, unless the nature and severity of the hazards require more. Selecting the most appropriate P-statements requires professional judgement – the classification determines which statements are available, but the supplier chooses the most relevant ones for the specific product and its intended use. If the product is supplied to the general public, at least one disposal statement should be included.
Label Size and Pictogram Size Requirements
CLP specifies minimum label and pictogram dimensions based on the capacity of the package. These requirements ensure that hazard information remains legible across different container sizes.
For packages up to 3 litres, the label should be at least 52mm x 74mm where possible, with pictograms no smaller than 10mm x 10mm (recommended 16mm x 16mm). For packages between 3 and 50 litres, the minimum label size is 74mm x 105mm, with pictograms at least 23mm x 23mm. For packages between 50 and 500 litres, labels should be at least 105mm x 148mm, with pictograms at least 32mm x 32mm. For packages over 500 litres, the minimum label size is 148mm x 210mm, with pictograms at least 46mm x 46mm.
Each hazard pictogram must cover at least one-fifteenth of the minimum label area dedicated to CLP information, and no pictogram may be smaller than 1cm². Where label space allows, pictograms should be enlarged beyond the minimum to maintain visual proportion with the packaging.
While the current GB CLP Regulation does not specify a mandatory font size for label text, Article 31 requires that text must be of a size, spacing, and contrast that makes it easily readable. In practice, 1.2mm x-height is considered the practical minimum for legibility. At PID Labelling, we produce hazard labels and warning labels in the full range of CLP-compliant sizes, with clear, durable printing that meets every readability requirement.
Small Packaging and Fold-Out Labels
Fitting all required CLP information onto small containers can be a genuine challenge. The regulation acknowledges this and provides several concessions for smaller packages.
For packages where the minimum label dimensions cannot be achieved, CLP allows the use of fold-out labels (sometimes called booklet labels), tie-on tags, or outer packaging to carry the full labelling information. With fold-out labels, the outer face must display the pictograms, product identifier, signal word, and supplier details. The full set of hazard and precautionary statements can appear on the inner panels.
For very small packages (typically 125ml or less), there are reduced labelling provisions under Articles 29 and 34 of CLP. These allow certain label elements to be omitted where the full information cannot reasonably be accommodated, provided the hazard class is of lower severity. However, the pictograms, signal word, product identifier, and supplier name and telephone number must always appear on the immediate container at minimum.
These concessions only apply where lack of space is genuinely caused by the container size – not because non-mandatory information (such as marketing text, excessive branding, or unnecessary additional languages) has consumed the available space.
How to Classify Your Substances and Mixtures
Classification is the foundation of CLP compliance. Before you can label a product, you must determine its hazard profile through a systematic assessment.
For substances, the starting point is the GB Mandatory Classification and Labelling (MCL) list. If your substance appears on this list, you must apply the harmonised classification specified there. The GB MCL list is maintained by HSE and is available on their website. If your substance does not have a harmonised classification, you must self-classify it based on available data – test results, scientific literature, previous assessments, and analogous substance data.
For mixtures, classification is always through self-classification. You assess the mixture based on the classifications of its component substances, using the calculation methods and threshold concentrations set out in the CLP Regulation. For health hazards, you may use test data on the mixture itself if available, or apply calculation methods based on ingredient classifications. For physical hazards, testing the mixture is generally required. For environmental hazards, calculation methods based on ingredients are the standard approach.
The CLP Regulation sets specific concentration limits and cut-off values that determine when a component substance triggers classification of the overall mixture. These vary by hazard class – for example, a carcinogenic substance might trigger classification of the mixture at a lower concentration than an irritant substance would.
If you are uncertain about classification, seek professional advice. Incorrect classification leads to incorrect labelling, which creates both safety risks and legal liability.
Products Exempt from CLP
Several categories of products are exempt from CLP classification and labelling requirements because they are covered by their own sector-specific legislation. These exemptions apply to the finished product in the form in which it reaches the end user. The raw materials and intermediate chemicals used to make these products are still subject to CLP throughout the supply chain.
The main exemptions cover medicines (human and veterinary), medical devices, cosmetic products, food and food additives, food flavourings, and feeding stuffs used in animal nutrition. Radioactive substances and mixtures are also exempt, as are substances and mixtures subject to customs supervision that are in temporary storage or free zones.
The transport of dangerous goods by air, sea, road, rail, or inland waterways is governed by separate transport regulations rather than CLP, though there is interaction between the two systems regarding classification criteria.
A critical point: the exemption applies to the final product as presented to the consumer, not to the entire supply chain. For example, the raw chemical ingredients used to formulate a cosmetic product must be CLP-compliant at every stage of supply up to the point where they become part of the finished cosmetic. Only the finished product on the retail shelf is exempt.
CLP and UK REACH: How They Work Together
CLP and UK REACH are companion regulations that work in parallel. While CLP governs the classification, labelling, and packaging of chemicals, UK REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) deals with the registration, evaluation, and restriction of chemical substances.
The two regulations interact in several important ways. A substance’s CLP classification can trigger additional obligations under UK REACH. For example, substances classified as carcinogenic, mutagenic, or toxic to reproduction (CMR) categories 1A or 1B may be identified as Substances of Very High Concern (SVHC) under UK REACH, which can lead to authorisation requirements or restrictions on use.
Safety Data Sheets (SDS), which are required under UK REACH, must reflect the CLP classification of the substance or mixture. The SDS serves as the primary tool for communicating hazard information along the supply chain, complementing the label information.
Compliance with one regulation does not excuse non-compliance with the other. Both must be satisfied independently.
Safety Data Sheets (SDS)
While not strictly a CLP labelling requirement, Safety Data Sheets are closely connected. UK REACH requires suppliers to provide an SDS for any substance or mixture classified as hazardous under CLP. The SDS is a 16-section document providing detailed information on hazards, safe handling, storage, disposal, and emergency measures.
The classification information on the SDS must be consistent with the CLP label. Section 2 of the SDS covers hazard identification and must list the same classification, pictograms, signal word, and hazard/precautionary statements that appear on the label. Any inconsistency between the SDS and the label indicates a compliance failure.
It is worth noting that GB and EU SDS formats are currently aligned, but as UK REACH and EU REACH diverge over time, differences may emerge. The format requirements under EU REACH Annex II that were updated after the UK’s exit from the EU do not apply in Great Britain.
Enforcement and Penalties
In Great Britain, the Health and Safety Executive (HSE) is the primary enforcing authority for GB CLP, through its Chemicals Regulation Division (CRD). Local authority Trading Standards officers also play an enforcement role, particularly for consumer products.
It is a criminal offence to fail to comply with the duties under GB CLP, or to cause another person to fail to comply. Enforcement action can include improvement notices, prohibition notices, and prosecution. Where HSE determines prosecution is appropriate, cases may be tried either summarily (in Magistrates’ Courts in England and Wales, or Sheriff Courts in Scotland) or on indictment (in Crown Courts or by solemn proceedings).
The penalties for non-compliance are significant. Conviction can result in unlimited fines and/or imprisonment. The court determines the appropriate penalty based on the circumstances of the offence. Beyond formal penalties, non-compliance can trigger product recalls, damage to business reputation, and civil liability if incorrect labelling contributes to harm.
GB CLP applies in parallel with other legislation, including UK REACH, the General Product Safety Regulations, the Biocidal Products Regulation, and the Plant Protection Products Regulation. Compliance with CLP does not excuse failure to comply with these other laws.
To report a concern about CLP non-compliance, contact HSE’s Chemicals Regulation Division at CRD.Enforcement@hse.gov.uk. For Northern Ireland, contact HSE Northern Ireland (HSENI).
Common CLP Labelling Mistakes
Even experienced businesses make CLP labelling errors. Here are the most common mistakes we see, and how to avoid them.
Using outdated classifications. Hazard classifications are updated regularly as new scientific evidence emerges. The GB MCL list is a living document. If you classified a product five years ago and have not reviewed it since, there is a real chance the classification has changed. Set a schedule to review your classifications at least annually against the current GB MCL list.
Missing or incorrect pictograms. Using the wrong pictogram, omitting a required one, or failing to apply precedence rules correctly are all common errors. Each pictogram must correspond to the actual classification – not to a general sense of what the product does. Verify every pictogram against the classification criteria.
Using H-codes instead of full statements. The label must carry the full written hazard statement. You cannot simply print “H225” – you must print “Highly flammable liquid and vapour”. The H-code may optionally appear alongside the statement for reference, but it cannot replace it.
Illegible text. Labels must be readable when the container is set down normally. Cramming text onto a small label so it cannot be read defeats the entire purpose of CLP. If the container is too small for all required text, use fold-out labels or outer packaging – do not reduce the text below readable size.
Inconsistent information across labels and SDS. The hazard classification, pictograms, signal word, and H/P statements on your label must exactly match Section 2 of your Safety Data Sheet. Any discrepancy signals a compliance problem.
Relying on a third-party classification without verification. If you import a product, the supplier’s classification may reflect EU CLP rather than GB CLP, or may simply be wrong. You are legally responsible for the classification of products you place on the GB market, regardless of what a foreign supplier has told you.
Practical Steps to CLP Compliance
Getting CLP right does not have to be overwhelming. A systematic approach makes it manageable even for small businesses handling multiple products.
Step 1: Identify your substances and mixtures. List every chemical product you place on the market, including any you reformulate, repackage, or import. Do not forget ancillary products like cleaners, solvents, or maintenance chemicals.
Step 2: Classify each product. Check the GB MCL list for harmonised classifications. For substances not on the list, and for all mixtures, conduct a self-classification using available data. Consider engaging a qualified consultant if you lack in-house expertise.
Step 3: Determine your label elements. For each classification, identify the required pictograms (applying precedence rules), signal word, hazard statements, and appropriate precautionary statements. Draft the complete label text.
Step 4: Design and produce your labels. Ensure labels meet size requirements for your package, with legible text and correctly formatted pictograms. Use a professional label printer who understands CLP requirements – our chemical labels are produced to exacting specifications with durable materials that withstand the conditions your products face in storage and use.
Step 5: Update your Safety Data Sheets. Ensure Section 2 of every SDS matches the corresponding label exactly. Distribute updated SDS to all customers in the supply chain.
Step 6: Establish a review process. Monitor the GB MCL list for updates, review classifications when products are reformulated, and audit your labels periodically. Keep records of your classification decisions and the data supporting them.
Recent EU CLP Changes (2024) and UK Impact
In November 2024, the EU published Regulation (EU) 2024/2865, a significant revision of the EU CLP Regulation. These changes entered into force on 10 December 2024, with most requirements becoming mandatory between July 2026 and January 2027. While these changes apply directly in the EU (and in Northern Ireland under the Windsor Framework), they do not automatically apply in Great Britain.
The key EU changes include mandatory minimum font sizes for label text, requirements for black text on a white background, minimum line spacing of 120% of font size, new rules for fold-out labels, requirements for EU-based supplier details on labels, mandatory hazard information in advertisements, and specific provisions for refill stations. New hazard classes have also been introduced for endocrine disruptors and substances with persistent, bioaccumulative, and toxic (PBT) properties.
At the time of writing, it is not clear whether the UK government will adopt equivalent changes for GB CLP. There is currently significant industry discussion about this, with some stakeholders opposing alignment on the grounds that the new formatting requirements (particularly minimum font sizes) would force major label redesigns and increase costs. UK businesses that also supply the EU or Northern Ireland market should prepare for these changes regardless of what happens in GB CLP, as dual compliance will be necessary.
We will update this guide as the regulatory position becomes clearer. In the meantime, businesses supplying both markets should begin assessing the impact of the EU changes on their label designs and production processes.
Getting Your CLP Labels Right
CLP labelling protects your workers, your customers, and your business. Getting it wrong risks prosecution, product recalls, and serious harm to people and the environment. Getting it right starts with proper classification and ends with professionally produced labels that communicate every required element clearly and durably.
At PID Labelling, we have extensive experience producing chemical labels, hazard labels, warning labels, and pesticide and fertilizer labels that meet the full requirements of the GB CLP Regulation. We also produce tactile warning labels with raised varnish finishes for products that require them under CLP provisions for consumers with visual impairments.
Whether you need a complete set of CLP-compliant labels for a new product range, a label redesign to accommodate updated classifications, or short-run digital labels for small batches, our team can help. We print on durable materials that withstand chemical exposure, UV light, and harsh storage conditions – because a label that degrades in use is a label that fails to do its job.
Need CLP-compliant chemical labels? Call us on 01332 864895 or get in touch to discuss your requirements.
Disclaimer: This guide is provided for general information purposes only and does not constitute legal advice. For definitive guidance on marine transport labelling requirements for your specific products, consult the Maritime and Coastguard Agency, your shipping line, or a dangerous goods specialist. PID Labelling accepts no legal responsibility for the accuracy of the information in this guide.