Labelling of products is perhaps more important than the SDS in terms of getting a message on product safety to the true point of use. GHS intends to harmonize this across the globe and has significantly achieved this.
The Label must align with the information provided in the SDS and, in that regard, the Label is essentially a concise and visual representation of the key information contained within the associated SDS. What is different, however is the requirement for further brevity and a clear, visual indicator for the user as to the hazards of the product contained within a package or container.
The fundamental principle of labelling is that it applies to hazardous substances and mixtures only. If non- hazardous, the obligations of CLP do not apply to the product and CLP-labelling is not required. Neither is it required to state “non-hazardous”.
Key Changes in the CLP Update
On 10 December 2024, the new CLP Regulation (EU) 2024/2865 entered into force, amending the existing legislation on the classification, labelling and packaging of substances and mixtures (Regulation (EC) No 1272/2008). The most significant changes concerning the topic of this report include:
• Fold-out labels – they can be applied to products regardless of size, and the contents of the front, inside and back sides of the label are set out;
• New deadlines for updating labels – in the case of the addition of a new hazard class or a more stringent classification of the product, the supplier must update the label without undue delay and no later than 6 months after obtaining the new information;
• Introduction of a minimum font size – requirements vary depending on package size
• New required label characteristics – white background, distance between lines at least 120 of the font
size, black single font without serifs, easily legible;
• Digital label – addition of digital format and specified requirements.
There are different dates of applicability for the new rules, but obligations will generally apply from 1 July 2026. However, some rules, such as those on label formatting, are applicable from 1 January 2027. Substances and mixtures placed on the market before these dates do not need to be re-labelled and re-packaged based on the new rules. They can continue to be in the supply chain until 1 July 2028 and 1 January 2029, respectively.
Label Elements Required Under CLP/GHS
In the EU, Article 17(1) hazardous substances or mixtures must have a label that includes the following elements:
• Name, address and telephone number of the supplier(s);
• Nominal quantity of the substance or mixture in the package made available to the general public, unless this quantity is specified elsewhere on the package (this is only required if it’s being sold as a consumer good to the general public – does not apply for professional users);
• Product identifier(s);
• Hazard pictograms;
• Signal words;
• Hazard statements;
• Precautionary statements;
• Supplemental information (Including UFI).
Languages
In the EU, hazardous substances or mixtures must have a label written the official language of the Member State where the substance or mixture is placed on the market (Article 17 (2)).
These official languages can be found here.
Revision Obligations
According to Regulation (EU) 2024/2865 the supplier must update the label without undue delay and in any event no later than 6 months after the results of the new evaluation are obtained (Article 30 (1)) if any of the following applies:
• A change in classification or labelling
• Addition of a new hazard class
• More severe classification
• New supplemental labelling elements are required under Article 25
If any other labelling changes are required, the supplier must update the label without undue delay and in any event no later than 18 months after obtaining new information, in accordance with Article 30(2). However, where changes are triggered by a delegated act, the deadline for revising the label may differ and will be set out in respective document. As with all CLP obligations, enforcement of CLP is the responsibility of the individual EU country competent authority and country specific inspection and enforcement procedures.
Details of the Supplier
It is important to note that for the EU it will be required to include EU legal entity details on the label. Similarly, after Brexit, it is now mandatory to have UK legal entity details on the label of the product marketed in the UK. Further considerations and conclusions on this aspect can be found here.
Product Identifiers
The term used for identification of the substance or mixture must be the same as that used in the (material) safety data sheet and include at least the following:
• Identification number from Annex VI to CLP
• Identification number from C&L Inventory
• CAS Number and IUPAC Name
• IUPAC or other name
Nominal Quantity
In accordance with Article 17(1) b, nominal quantity of the product made available to the general public (e.g. 250 ml) must appear on the label of the hazardous good. Products placed on the market though not made available for sale to the general public do not need to have this requirement.
Hazard Pictograms
For each specific classification, certain hazard pictograms are relevant. Currently there are nine different pictograms. While normally only one pictogram is assigned to an individual hazard class or category, some hazard differentiations are required to carry two pictograms (Article 19).
Note: A further pictogram for Endocrine Disruptors is being discussed and considered though not yet available
The colour and presentation of a label must allow the hazard pictogram and its background to be clearly visible, see CLP Article 31(2). Hazard pictograms shall be in the shape of a square set at a point, i.e. they shall appear as a diamond shape when the label is read horizontally, and must have a black symbol on a white background with a red border (see section 1.2.1 of Annex I to CLP). Each hazard pictogram shall cover at least one fifteenth of the minimum surface area of the label dedicated to the information required by CLP Article 17, but the minimum area shall not be less than 1 cm2.
For substances and mixtures classified for more than one hazard, several pictograms may be required for the label. As a general rule, the pictograms which reflect the most severe hazard category of each hazard class shall be included on the label.
An example of a hazard pictogram (GHS07). This pictogram applies to a number of skin and eye irritation
and sensitisation classes, along with Acute Toxicity and Specific target Organ Toxicities.
Signal Words & Hazard Statements
For each specific classification, a signal word may apply as adopted by GHS. If applicable, the label must include a signal word – this will either be ‘Danger’ or ‘Warning’ but never both (Article 20).
If the substance or mixture has a hazardous classification, there will be relevant hazard statements that must be included on the label. For example, if a substance or mixture had an acute oral toxicity category 4 classification, the hazard statement “Harmful if swallowed” (H302) would have to appear (Article 21).
The classification and labelling information on a substance can be found in Section 2 Hazard Identification of an EU SDS.
Precautionary Statements
The label must include relevant precautionary statements in accordance with Article 22. The format is a “P” followed by three digits. These are more advisory P-Statements than Hazard Statements, providing details of risk management measures to be adopted. The complete set of precautionary statements relevant for each hazard class and category/differentiation is listed by alphanumeric code in the tables indicating the label elements required for each hazard class in parts 2 to 5 of Annex I to CLP.
Duplication and redundancy should be avoided. Where the substance or mixture is supplied to the general public, one precautionary statement addressing the disposal of that substance or mixture as well as the disposal of packaging shall in general appear on the label, see CLP Article 28(2).
Normally, not more than six precautionary statements shall appear on the label, unless necessary to reflect the nature and the severity of the hazards. For some products, more than six precautionary statements might be needed.
The table below provides information on the codes used for hazard and precautionary statements.
one classification will yield one hazard statement, but from this may stem three to six possible precautionary statements. Expert judgement is needed to advise the selection of such precautionary statements.
Principles of Precedence
To limit the information on the label to the most essential information, principles of precedence support the selection of the most appropriate label elements for cases in which substances or mixtures have several hazardous classifications.
When this results in more than one hazard pictogram on the label, rules of precedence shall apply to reduce the number of hazard pictograms required. These are listed in Article 26 of CLP, and provide examples of where one pictogram may out-weigh another – usually the hazard pictogram for the most severe hazard category prevails:
• if the hazard pictogram ‘GHS01’ applies, the use of the hazard pictograms ‘GHS02’ and ‘GHS03’ shall be
optional, except in cases where more than one of these hazard pictograms are compulsory;
• if the hazard pictogram ‘GHS06’ applies, the hazard pictogram ‘GHS07’ shall not appear;
• if the hazard pictogram ‘GHS05’ applies, the hazard pictogram ‘GHS07’ shall not appear for skin or eye
irritation;
• if the hazard pictogram ‘GHS08’ applies for respiratory sensitisation, the hazard pictogram ‘GHS07’ shall
not appear for skin sensitisation or for skin and eye irritation;
• if the hazard pictogram ‘GHS02’ or ‘GHS06’ applies, the use of the hazard pictogram ‘GHS04’ shall be optional.
All hazard statements resulting from the classification shall appear on the label, unless there is evident duplication or redundancy.
Unnecessary precautionary statements should be omitted from the label. Unless necessary to reflect the nature and severity of hazards, no more than six precautionary statements should appear on a label.
Dimensions of Label
Section 1.2 of Annex I to CLP sets out the dimensions required. Label size is as a function of package size, as can be seen in the table below.
Label and Pictogram Sizes for Various Package Volumes
The Hazard Pictogram
Each hazard pictogram must cover at least one fifteenth of the surface area of the label, but the minimum area must not be less than 1 cm2. These should be black against a white background surrounded by a red diamond. The overall label should appear on a white background with black, legible text. The color and presentation should be such that the hazard pictogram stands out clearly. Pictograms must be of the exact format as seen in the example shown in the figure above, and these are detailed in section 1.2.1 of Annex I of CLP.
Aesthetics
As specified in Article 31, the label must be fully legible horizontally when the package is set down normally. It should be firmly affixed to the surface of the packaging immediately containing the substance or mixture. Since the introduction of Regulation (EU) 2024/2865, the label may be presented in the form of a fold-out label regardless of packaging size.
Label elements should be marked indelibly, should stand out from the background and be of such size and spacing to be easily read.
General Tips on Font Size
With introduction of (EU) 2024/2865 Regulation, amending the CLP Regulation, the font size is now specified directly in the legal text (previously the recommendations were more qualitative than quantitative, specifying that the font size should allow for the label to be legible, but not providing the exact sizes).
As set out in section 1.2.1.4. of Annex I of CLP font size specification refers to the height of the lowercase “x” and is based on the size of the container as below:
The text on the label must be black on a white background, the distance between the lines must be at least 120% of the font size, and the font should be easily readable, without serifs, with appropriate spacing between the letters.
Supplemental Information
CLP Article 25 introduces the concept of ‘supplemental information’ which is intended to incorporate additional labelling information beyond that listed in CLP Article 17(1) a to g. This additional labelling information can be divided into two categories obligatory and non-obligatory information. Both types count as ‘supplementary information’ under CLP and must be located in the section for supplemental information on the label and appear in the same languages as the other CLP label elements.
An example of obligatory supplemental information would be the phrase “EUH032 – “Contact with acids liberates very toxic gas”. This example is a supplemental statement taken over from DPD which applies to certain substances/mixtures. Most of this obligatory supplemental information is taken over from DSD/DPD and therefore usually only applies in the EU. For any supplemental hazard statements included in CLP, a new “EU” codification system is introduced, to distinguish them from the hazard statements originating from the United Nations Globally Harmonised System (UN GHS). These are easily recognizable with a EUH code (European specific hazard code).
After the implementation of Regulation (EU) 2024/2865, the supplemental information described above may now be provided on a digital label and, if so, may be omitted from the physical label. Detailed requirements for digital labels are outlined in Article 34a and Article 34b of CLP.
Non-obligatory supplemental labelling information, the content of which is up to the discretion of the supplier, is not part of the labelling requirements under CLP. It can include, for example, specific product information or particular instructions for use. It cannot contradict obligatory label elements and must be consistent with the classification of the substance or mixture.
Digital Label
With the entry into force of Regulation 2024/2865, a new labelling format has been adopted. According to the newly added Article 34a, label elements for substances and mixtures must be provided on a physical label, but they can also be presented in digital form. Suppliers may provide certain label elements digitally only, as long as they are not essential for the safety of the user or the protection of the environment.
General rules and technical requirements for digital labels are set out in Article 34b and include the following aspects:
• All label elements must be provided together and separately from other information;
• Information must be searchable and accessible to all users in the Union for at least 10 years;
• Digital labels must be free of charge, without registration or installation requirements;
• Information must be accessible to vulnerable groups and presented in a user-friendly manner;
• Digital labels must be accessible with no more than two clicks and compatible with widely used technologies;
• Language choice must not be conditioned by geographical location.
Exemptions Due to Small Size, Shape or Form
Where the packaging of a substance or a mixture is either in such a shape or form or is so small that it is impossible to meet the requirements, the label elements may be provided on a tie-on tag or an outer packaging.
The label on any inner packaging shall contain at least hazard pictograms, the signal words, the product identifier and name and telephone number of the supplier of the substance or mixture.
Exemptions for Packages of a Capacity of 125 ml or Less
The label elements mentioned in column 2 of Table 1 may be omitted from the label of packages when the substance or mixture is classified for the hazard classes or categories listed in column 1. However, when the substance or mixture is classified for further hazard classes not listed in Table 1 the label elements related to these other hazard classes still need to be included.
Tactile Warning of Danger
Inclusion of a tactile warning of danger (TWD) on the packaging enables blind or visually impaired people to ascertain if the packages contain a hazardous mixture.
Product packaging must be fitted with a TWD, independent of its capacity, where supplied to general public and classified for one (or more) of the following hazard classes:
• acute toxicity 1-4 – oral (H300, H301 and H302), dermal (H310, H311 and H312) and inhalation
(H330, H331 and H332),
• skin corrosion cat. 1, subcategories: 1A, 1B and 1C (H314),
• germ cell mutagenicity 2 (H341),
• carcinogenicity 2 (H351),
• reproductive toxicity 2 (H361);
• respiratory sensitisation 1, 1A and 1B (H334),
• STOT 1 or 2 (H370, H371, H372 and H373),
• aspiration hazard 1 (H304),
• flammable gases 1 and 2 (H220 and H221),
• flammable liquids 1 and 2 (H224 and H225) or
• flammable solids 1 and 2 (H228)
According to CLP Annex II, section 3.2.1.2 a TWD is not required for the following:
• transportable gas receptacles.
• aerosols and containers fitted with a sealed spray attachment containing substances or mixtures classified as presenting an aspiration hazard, unless they are classified for one or more of the other hazards mentioned above.
The TWD must be located in such a way that other embossed patterns do not cause confusion. Exact placement of the TWD has to follow EN IS standard 11683.
The TWD have to remain tactile during the expected period of use of the package under normal handling conditions. It is not required on outer packaging such as a cardboard box protecting a glass bottle.
Technical aspects for the TWD, according to Annex II to the CLP Regulation, should be according to EN ISO
standard 11683.
Child-resistant Fastening
Child-resistant package is a type of packaging build of a container and appropriate closure which is difficult to open (or gain access to the contents) for young children under the age of fifty-two months, but which is not difficult for adults to use properly (according to EN ISO 8317).
Annex II refers to two types of child-resistant fastenings (CRF):
• non-reclosable package – a package which, when all or part of the contents have been removed, cannot be properly closed again, for example a blister pack or air freshener refills;
• reclosable package – a package (for example a one litre bottle or a five-litre container) which after it has been initially opened, can be reclosed, and re-used numerous times without loss of security.
The above types of fastenings have to follow the below mentioned standards:
• EN ISO 8317 (reclosable packages)
• CEN EN 862 (non-reclosable packages)
Product packaging must be fitted with a CRF, independent of its capacity, where supplied to general public and classified for one (or more) of the following hazard classes:
• classified for acute toxicity 1-3 – oral (H300 and H301), dermal (H310 and H311) and inhalation (H330 and H331),
• STOT-SE 1 (H370),
• STOT-RE 1 (H372),
• Skin corrosion cat. 1, subcategories: 1A, 1B, 1C (H314), or
• Classified as presenting an aspiration hazard (H304) with the exception of:
– substances and mixtures that are placed on the market in the form of aerosols or in a container fitted with a sealed spray attachment,
• containing methanol at a concentration greater or equal to 3%, or • dichloromethane at a concentration greater or equal to 1%.
UFI Placement and Positioning
Inclusion of the UFI on the label will follow the same rules regarding the font size and aesthetics as are applicable to other label elements (therefore previous parts of this guidance can be consulted to obtain appropriate reference).
UFI is not required to be placed directly on the label, however it should be in close proximity of label elements. UFI should follow the specific rules regarding formatting, please see below:
It is important to note that the acronym UFI has to precede the actual UFI-code (16-difit alphanumeric code).
Fold-out Labelling
With the introduction of Regulation (EU) 2024/2865, the rules for the use of fold-out labels have changed. It is now permitted for products of all sizes to have a fold-out label, applying the rules on application and formatting to ensure good readability, and the specific requirements for the content of the front, inner and back pages.
Technical allocation of label elements on overlap roll/accordion label type (fold-out label approach) Section 1.2.1.6. of Annex I to CLP Regulation describes fold-out label to generally consist of three parts:
• Front page (top leaf);
• Inside page(s);
• Back page (firmly attached to the packaging);
Front page content
• the product identifier (Article 18(2) for substances, Article 18(3)(a) for mixtures); Please note that for mixtures, the product identifier on the front and back page does not need to specify all the components contributing to the classification of the mixture;
• hazard pictogram(s);
• signal words in all languages of the label;
• nominal quantity (packages made available to the general public, unless specified elsewhere in the package)
• contact details of supplier(s) (name, address and phone number)
• a reference to the full safety information inside the fold-out label, for example: “safety information, see inside” in all languages of the label or a symbol to inform a user that the label can be opened and to illustrate that additional information is available on inside pages;
• an abbreviation of the language (country code or language code); to avoid non-standard or confusing abbreviations it is recommended to use the language code according to e.g. ISO 639-1;
• the unique formula identifier (where applicable), unless printed or affixed on the inner packaging
Inside page(s) content
• full labelling information (except for the hazard pictogram and the supplier identification) as required by Article 17(1) of CLP (including supplemental information) for each language mentioned on the front page and grouped by language, for example one language per page;
• an abbreviation of the language featured at the top of each of the inside pages (country code or language code).
Back page content
• The back page should repeat the information given on the front page, except for the indication of the different languages in the inner layers.
Quality and design
According to the CLP Labelling Guidance, general rules, as in case of standard labelling, should be followed for these types of labelling:
Other requirements will also follow standard CLP labelling requirements, to include:
Durability
Taking into account the different situations that may occur during normal handling and use of the packaging (the contents of the package may dissolve the printing, or the users may read the label several times), it is clear that the fold-out label must be sufficiently durable to maintain its functionality under repeated use conditions (as applicable) for the entire life span of the product. This can be achieved for example by protective coating of the label and using plasticized pages. The back page of a fold-out label should be firmly attached to the packaging to resist normal handling and use. The pages should not be easily detachable from each other.
Readability
The information in the fold-out label should be easily read. In the case of a booklet, page numbers can be considered. The languages should be ordered in a logical way, e.g. alphabetically.
Easy access to the information
The information in the fold-out label should be easily accessible by allowing easy opening and reclosing of the label by the user. This can be ensured for example by using a “Pull tab” – a small area of the label which allows lifting it easily from its backing sheet. Easy access to the information (and readability) can also be also improved by featuring one language per inner page of the fold-out label.
Visual Interpretation
Regulatory References
Classification Labelling and Packaging of Hazardous Substances and Mixtures is governed in the EU by the CLP Regulation. This is aligned with GHS Revision 7. Note – The United Kingdom chose to adopt the same Legislation after their exit from the European Union.
Key Literature:
Guidance on labelling and packaging in accordance with Regulation (EC) No 1272/2008
ECHA Questions & Answers CLP Regulation
Published April 24, 2025
This article was generated with the assistance of Artificial Intelligence.