Mixture components identified on CLP label

Mixture components to be identified on CLP label

Substances contained in mixtures classified for CLP are required to be identified on the label:

• if they contribute to the classification of the mixture and are hazardous to health, that is acute toxicity, skin corrosion or serious eye damage, germ cell mutagenicity, carcinogenicity, reproductive toxicity, respiratory or skin sensitisation, specific target organ toxicity (STOT) or aspiration hazard
• if the substance is a sensitiser at EUH208 level (0.1 – 1% sensitiser class 1 or 1B, 0.01 – 0.1% sensitiser class 1A)
• if a substance has been Authorised for specific uses, that is it is published on the Authorisation list, the substance authorisation number must be included on the label, which implies that its name should be on the label as well.  For the current Authorisation list, see https://ttenvironmenta.wpengine.com/clp-knowledgebase/svhc-list/ .

Substances which don’t currently need to be identified on the label include:

• substances which contribute to the classification of the mixture but only have physical and/or  environmental hazards can be omitted from label, but must be identified on the SDS
• substances which have a Workplace Exposure Limit and are present at or above 1% in the mixture
• substances which are PBT or vPvB and are present at or above 0.1% in the mixture
• substances which are on the SVHC candidate list, but which have not been authorised, and which are present at or above 0.1% in the mixture

Many of the substances which don’t need to be identified on the label may need to be identified on the Safety Data Sheet.  For more information on which mixture components should be identified on the SDS, see: https://ttenvironmenta.wpengine.com/clp-knowledgebase/mixture-components-identified-on-sds/.

Note that hazardous mixtures contained in another mixture are not required to be identified on the CLP label, only the hazardous substances within that component mixture.

Layout of substance names

The substances in the mixture should be identified below or after the trade name with  the word “contains”, and then their chemical name.  There is no need for an identification number, only the chemical name (although identification number is required on the SDS).  Example: TTE Bleach, contains sodium hypochlorite and sodium hydroxide.

The CLP regulation states that a maximum of four substances should be identified after “contains”, “unless more than four names are needed to reflect the nature and the severity of the hazards”.  In the case of sensitisers, it is considered good practice to name all of these which are present down to EUH208 level, so that anyone who is already sensitised to the substance is aware that they are in the mixture.

Sensitiser names layout

Where sensitisers give rise to H317 or H334 classification, they should be identified after “contains”.  Where sensitisers give rise to EUH208 levels, they should be included in the EUH 208 statement, that is “Contains (name of sensitising substance). May produce an allergic reaction.”

However, in some instances, there may be sensitisers present at both levels, or there may be other health hazards giving rise to classification, and EUH208 levels of sensitisers.  In this case, CLP allows you to add the EUH208 sensitiser names after “contains”, and omit the EUH208 phrase.  This is so that all of the information on component substances can be placed together on the label.