Original Article from CIRS

Starting from 1 June 2015, the classification and labeling of both substances and mixtures will be affected only by the Classification, Labeling and Packing (CLP) Regulation. Companies are required by CLP to classify, label and package their chemicals before placing them on the market.

What is CLP?

CLP stands for the Regulation (EC) No 1272/2008 on the Classification, Labeling and Packaging of substances and mixtures. CLP introduces the United Nations Globally Harmonized System (UN GHS) for classification and labeling of chemicals into Europe. CLP entered into force on 20th January 2009.

Connection Between REACH & CLP

  • Both contain hazard communication tools: labeling rules are set out in CLP whereas the Safety Data Sheet (SDS) rules are set out in REACH; a CLP label must always be used together with SDS.
  • The classification of a substance is one mandatory part of REACH registration dossier whereas the classification criteria are set out in CLP regulation;
  • Substances registered under REACH before 30 Nov 2010 do not require further C&L notification.

The Transitional Period of CLP Regulation

The CLP Regulation will replace Dangerous Substances Directive 67/548/EEC (DSD) and Dangerous Preparations Directive 1999/45/EC (DPD) in a stepwise approach during a transitional period. On 1 June 2015, both directives will be fully repealed.

For example, before 1 Dec 2010, a substance shall be classified according to DSD. CLP classification is optional.

Between 1 Dec 2010 and 1 June 2015, a substance shall be classified according to both DSD and CLP. Both classification shall be given in Safety Data Sheet and communicated down the supply chain.

After 1 June 2015, a substance shall only be classified according to CLP.

The details of time frame can be found in the table below:

Time Range

For Substances

For Mixtures



Labeling and Packaging


Labeling and Packaging

20 January 2009 to
1 December 2010

In accordance with DSD; CLP is optional

In accordance with DSD; if substance is classified under CLP, it shall be labeled and packaged under CLP

In accordance with DSD; CLP is optional

In accordance with DPD; if substance is classified under CLP, it shall be labeled and packaged under CLP

1 December 2010 to
1 June 2015

In accordance with both DSD and CLP

In accordance with CLP only

Same as above

Same as above

From 1 June 2015

In accordance with CLP only

In accordance with CLP only

In accordance with CLP only

In accordance with CLP only

How to Comply with CLP?

The CLP Regulation, Article 46, on Enforcement and Reporting, states that “Member States shall take all necessary measures, including maintaining a system of official controls, to ensure that substances and mixtures are not placed on the market, unless they have been classified, labeled, notified and packaged in accordance with this Regulation”.

Generally speaking, companies shall classify substances or mixtures, submit C&L notifications to ECHA, and label and package their products in accordance with the CLP regulation. CLP compliant Safety Data Sheet containing the CLP classification and labeling shall also be prepared and communicated to downstream users.

Find out more information about how enterprises comply with CLP and the roles and obligations by clicking here

How CIRS can Assist You in Complying with CLP?

We provide end-to-end solutions to CLP compliance. We can help you classify your substances and mixtures according to CLP, notify the classification and labeling of your products to the C&L Inventory, prepare CLP compliant labels and the latest Safety Data Sheets.

Even though there are many guidance documents on how to prepare CLP compliant label, it is much easier and less time-consuming for you to outsource this job to us.

  • Regulatory advice on the implications of CLP and REACH for your company;
  • Re-classification and re-labeling of your substances or mixtures;
  • Preparation of CLP compliant labels;
  • Notification to the Classification & Labeling Inventory (C&L notification);
  • New Safety Data Sheets in accordance with CLP & REACH.

To find out more services that we provide, please click here.

About CIRS

CIRS a leading provider of comprehensive chemical compliance services for companies doing businesses in/with EU and China with a strong focus on chemical compliance.

With a strong presence in EU and China, CIRS has provided cost-effective regulatory support to over 3,000 companies while doing businesses in both the EU and China. CIRS is the largest REACH only representative in the world. Since 2007, we have:

  • pre-registered over 10,000 substances;
  • acted as only representative for over 2,400 non-EU companies;
  • served clients in more than 25 countries;
  • registered over 800 substances to date;
  • prepared over 3000 REACH SDS and CLP labels every year

CIRS is a recommended service provider by China Inspection and Quarantine Bureau, the US Mission to the EU and IDA. CIRS is also a member of Helsinki REACH Centre.

Contact Us

  • CIRS China
    Hangzhou CIRS Co. Ltd (CIRS China)
    11F Building 1, Dongguan Hi-Tech Park, 288 Qiuyi Road, Binjiang District, Hangzhou 310052, China
    Tel: +86-571 8720 6574 | Fax: +86-571 8720 6533