The CLP Classification Sequence
When you set out to classify a product for CLP, it can be easy to dive straight into classifying from first principles, but this may not be the best approach. There is a lot of information available to you, particularly for substances, which you should use first, rather than thinking you need to do all the work yourself.
When classifying for CLP and writing SDSs, it is important to keep your end users in mind, and to think about how they handle and use your product. What you would want to know if you were using the hazardous material in their context, eg in the lab, or as a consumer, or in an industrial process. How might they be exposed to the material? What information do they need in case they are exposed to it? The more information you have on this, the more useful your hazard communications are likely to be.
Don’t forget to keep all of your notes and completed forms for 10 years after the date of last supply, for more information see here: https://ttenvironmenta.wpengine.com/clp-knowledgebase/keeping-clp-and-sds-information-on-file/ .
There are four main routes to classifying for CLP:
- Classifying a substance for CLP where you have registered it for REACH
- Classifying a substance for CLP where you have not registered it for REACH
- Classifying a mixture you have made yourself
- Classifying a mixture you have imported
Once you have obtained your CLP classification, that is the Hazard class, Hazard Category and H code, you then need to:
- classify the product for any EUH Statements
- go through the labelling procedure to generate the rest of the information you will need, (Signal Word, pictograms, H statements in full, P statements, other supplementary information)
- check that appropriate packaging is used for the product
- write a Safety Data Sheet, if one is required
Classifying a substance for CLP where you have registered it for REACH
If your substance has been registered for REACH, you are legally obliged to use the REACH registration classification, or one of the classifications if more than one has been registered.
Normally, this is not a problem, but sometimes the substance also holds a Harmonised Classification, and if there are any significant discrepancies between the two classifications, you may need to make a decision on which classification to use.
You can also download this flowchart as a pdf: CLP substance classification sequence where registered for REACH .
Classifying a substance for CLP where you have not registered it for REACH
If your substance has not been registered for REACH, and you have unique or unpublished data available for one or more hazard, you should use the appropriate classification forms for first principles: https://ttenvironmenta.wpengine.com/clp-knowledgebase/clp-/classification-from-first-principles .
However, this is a very unusual situation, and normally you may not have data on the substance, or have e.g. some basic physchem data.
Where you don’t have raw data, but have access to published CLP classification for substances, there is a hierarchy of published classifications:
- Harmonised classifications (most trustworthy, but do not cover every hazard)
- REACH CLP classifications (usually trustworthy, should contain information about every hazard)
- CLI entries (far less trustworthy)
Where both a Harmonised Classification and REACH dossier exist, you should review the CLP classifications side by side to compare; and where there are multiple CLI entries, this can also be a useful approach.
You can use the CLP classification comparison form to record the different CLP classifications, and your notes on what you think is most appropriate https://ttenvironmenta.wpengine.com/clp-knowledgebase/clp-classification-comparison-form/ .
If there are no published CLP substance classifications, but you have access to a CHIP or non-EU SDS with data, you should use the data in the SDS to classify from first principles: https://ttenvironmenta.wpengine.com/clp-knowledgebase/clp-/classification-from-first-principles .
If you only have a CHIP classification, you can use the “Annex VII” method to read-across from CHIP to CLP, although this is not as accurate as using data. This method can be used in conjunction with method C, above, if you have a CHIP SDS with partial data, for example. You can download our Annex VII reclassification form here: Form for Annex VII CHIP to CLP v1.1 29-06-2017.
If you don’t have any of the data described above, you can either use “read-across” to similar substances for the classification, but you would probably need expert help to do this; or you can test the substance and classify from first principles.
You can also download this flowchart as a pdf: CLP substance classification sequence where not registered for REACH v1.2.
Classifying a mixture you have made in-house for CLP
Like substances, mixtures have a sequence of actions to take for classification, depending on the information available to you. If you have made the mixture in-house, you already have the recipe (formulation), so the sequence for classification is relatively straightforward.
A. If you have test data on your mixture, this should be used to classify the mixture from first principles. (For physical hazards, such as flammability, testing is usually required as these properties are difficult to predict theoretically).
B. If you have test data for health hazards and environmental hazards on a closely related mixture, you may be able to use the “bridging principles”, that is a form of “read-across” and classify the mixture with the same classification as the tested mixture. The rules are given for each hazard at the front of the mixture classification forms.
C. Where there is no relevant test data, list out your current recipe: Mixture-component-form-v2.1-01-03-2017. You should then check that your mixture does not contain any new hazards caused by mixing incompatible components together, or that you have not inadvertently created any new substances by chemical reaction. We have two forms to help you with this, see: Checklist for new physical hazards of mixtures and Checking-for-new-substance-formation-in-a-mixture .
D. Once you have a complete list of everything in the formulation, you can obtain the CLP classification of all component substances, and list all of the hazardous components together, see: Hazardous-substance-component-identification-form v1.3 23-01-2018 .
You can then use the mixtures physical hazard screening form, see: and physical hazard tests, see: to classify any anticipated physical hazards ; and you can use the algorithm method in the CLP Regulation to classify the hazards of your mixture, see: https://ttenvironmenta.wpengine.com/clp-knowledgebase/clp-classification-for-mixtures/ .
E. For mixtures which are classified for CHIP, you also have the option to use the Annex VII method for classifying based on “read-across”, but this tends to be less accurate than using mixture method C, above, so it should be used with caution. See: Form for Annex VII method of reclassifying products from CHIP to CLP .
You can also download this flowchart as a pdf: CLP mixture classification sequence for mixture you have made 10-02-2018 .
Classifying a mixture you have imported for CLP
The sequence for classifying an imported mixture is the same as for a mixture you have made yourself, with the added complication that you may not have access to the recipe, and you may not have as much information on the hazards of the component substances. You may also be given a recipe by your supplier which shows the ingredients in the mixture, without taking into account any new substances made by reaction, or new hazards caused by mixing incompatibles.
You can also download this flowchart as a pdf: CLP mixture classification sequence for imported mixture 10-02-2018 .
After you have obtained your CLP classification
Once you have classified the substance or mixture for CLP-GHS hazards, you should:
- classify it for any applicable EUH hazards, see https://ttenvironmenta.wpengine.com/knowledgebase_category/euh-statement-classification/
- produce the rest of the labelling information, see https://ttenvironmenta.wpengine.com/knowledgebase_category/clp-labels/ using the CLP labelling sequence .
- check that the packaging is correct, see https://ttenvironmenta.wpengine.com/knowledgebase_category/packaging-for-supply-of-chemicals/
- and write the SDS, if one is required, see https://ttenvironmenta.wpengine.com/knowledgebase_category/safety-data-sheets/ .