What is CLP?
Definition of CLP
CLP is an EU regulation covering the Classification Labelling and Packaging of chemical materials for supply. The current consolidated version of the CLP Regulation (last updated 1st March 2018) is available from here: CLP consolidated version 1st March 2018 to 9th ATP and CHIP HCs removed.
As you can tell from the description we’ve given, the CHIP Harmonised Classifications have been removed, so only the CLP Harmonised Classifications are included.
Note that the current consolidated version does not include the following amendments:
- 10th ATP to CLP: 10th ATP to CLP
- Regulation on Harmonised Information Relating to Emergency Health Response (bringing in harmonised Poison Centre notification for hazardous mixtures, and the Unique Formulation Identified, UFI): Annex VIII to CLP March 2017
- 11th ATP to CLP: 11th ATP to CLP
A full list of all CLP regulations, updates and amendments is given at the bottom of this page for reference.
CLP is the EU’s method for implementing the UN’s Global Harmonised System of chemical classification (GHS).
CLP covers most aspects of communicating the hazards of chemicals to end users, except for Safety Data Sheets (SDSs), which are covered under the REACH regulation.
Prior to CLP, classification, labelling, packaging of chemicals for supply was covered under the CHIP regulations in the UK (as were SDSs before REACH was introduced).
CLP is mainly based on GHS, but also has some aspects of CHIP, so it can be considered to have two “parents”.
CLP also includes an obligation to notify all substances made and brought into the EU to the Classification and Labelling Inventory (CLI), along with their CLP classification, although any substance registered for REACH is considered to be automatically notified to the CLI. This notification did not exist under CHIP, prior to CLP.
To fully understand CLP, you need to look at the CLP regulation itself, and its relationship with GHS, CHIP and REACH.
Why “chemicals for supply”?
The definition of chemicals for supply is important, as this means it is for the person who is going to use the material, which means that they will open the package and potentially be exposed to it.
Legally, CLP applies to any chemical substance or mixture which is placed on the EU market, whether sold, given away, traded, or provided as a sample.
It applies to any quantity of chemical material, including very small lab samples, there is no “minimum amount” where you can avoid classifying a material for CLP. You also need to notify the material to the Classification and Labelling Inventory, again there is no “minimum amount”.
Chemicals can be classified under other systems as not being “for supply”
There are several different types of chemical classification systems in use in the EU, including:
- ADR, IMDG, RID etc for the Transport of Dangerous Goods
- Hazardous waste classification, for the treatment or disposal of wastes
- COMAH/ Seveso classification, for assessing whether a Major Accident could occur at a site
- COSHH, control of substances hazardous to health, for assessing the risks to end users at work
None of these are “for supply”, so they use their own classification systems. Transport is an entirely separate system, although there is overlap with the tests which are used for it and for CLP/GHS. However, hazardous waste, COMAH/Seveso and COSHH are based on CLP itself, so changes in CLP classification can affect these other classifications.