Understanding Regulation (EC) No 1272/2008 (CLP) – A Comprehensive Guide

At EaseCert, we believe clarity and precision matter, especially when you’re dealing with compliance in the EU chemicals and consumer-product landscape. Below is a comprehensive overview of the CLP Regulation: who it covers, what it requires (including the UFI/poison-centre dimension), and what you need to do. If you have questions or need support, we’re here.

1. What is CLP and why it matters

The CLP Regulation is officially titled “Regulation (EC) No 1272/2008 of the European Parliament and of the Council on classification, labelling and packaging of substances and mixtures”. It aligns EU law with the United Nations’ Globally Harmonised System of Classification and Labelling of Chemicals (GHS) and applies directly across all Member States. Its core aims are:

• To ensure a high level of protection for human health and the environment.
• To promote the free movement of substances, mixtures and some articles within the EU internal market under common rules.
• To harmonise criteria for classification, labelling and packaging so businesses and regulators speak the same language.

In short: if you place chemical substances or mixtures on the EU market, CLP matters.

2. Who is covered and what falls outside

Covered

Manufacturers and importers of substances and mixtures placed on the market in the EU. Downstream users and distributors also carry responsibilities—particularly around labelling, packaging and supply-chain communication.

Exceptions

CLP does not apply to certain categories such as:

• Radioactive substances or mixtures.
• Waste (which is regulated under separate legislation).
• Food and feed (which have their own regulatory regimes).
  
  

3. Core obligations under CLP

3.1 Classification

You must determine whether a substance or mixture displays hazardous properties (physical, health or environmental). Hazard classes include things like flammable liquids (physical hazard), acute toxicity (health hazard), aquatic toxicity (environmental hazard). The rules for how to classify are set out in Annex I of the Regulation.

3.2 Labelling

Once classified, you must label hazardous substances and mixtures appropriately. Label elements include:

• Supplier identity, product name/ID.
• Hazard pictograms, signal word (“Danger” or “Warning”).
• Hazard statements (H-statements), precautionary statements (P-statements).
• Nominal quantity, other mandatory text depending on hazard.

3.3 Packaging

The packaging must be designed to:

• Prevent contents from escaping.
• Be resistant to the contents.
• Be strong and sealable.

For certain high-risk substances additional requirements apply (e.g., child-resistant closures, tactile warning devices) depending on hazard class.

3.4 Notification and Inventory

Manufacturers/importers must notify classification and labelling information to the European Chemicals Agency (ECHA)’s CLP Inventory. For mixtures, the UFI (Unique Formula Identifier) requirements apply (for notification to poison centres) – see section 4 below.

4. UFI and Poison Centre Notification – What it means

What is the UFI?

The UFI is a 16-character alphanumeric code that links a specific hazardous mixture to the submission of information made to poison centres across the EU. For more detail, see the free course by The Open University: “Chemical Classification, Labelling and Packaging (CLP) Regulation”. The code helps poison centres identify the exact mixture in an emergency and provide accurate support.

When is UFI required?

The UFI requirement timelines are:

• Since 1 January 2021 for consumer and professional-use mixtures classified for health or physical hazards.
• From 1 January 2024 for industrial-use mixtures.
• Existing mixtures placed on the market before those dates must be updated by 1 January 2025.

How to generate and apply the UFI

1. Use the free online ECHA UFI Generator.
2. Include your company VAT number (or ECHA company key) and a unique internal mixture number.
3. Once generated you must:
• Include the UFI on the label of the mixture (prefix “UFI: XXXX-XXXX-XXXX-XXXX”) in a visible location.
• Submit a Poison Centre Notification (PCN) dossier in the harmonised format (Annex VIII of CLP) containing the UFI.
• Ensure the same UFI applies to all packaging variants of the same composition; any significant change triggers a new UFI and re-notification.

What data are required in the PCN submission?

The PCN must include:

• Full mixture composition with ranges of substances.
• Trade name, packaging details, product category.
• Hazard classification of the mixture and any “mixtures in mixture”.
• Toxicological and physico-chemical data relevant for emergency response.
• The UFI and notifier identity (manufacturer/importer).

Without correct notification and labelling you may not legally place a hazardous mixture on the EU market.

5. Relationship to other legislation

CLP sits alongside—but does not replace—other key chemical/product rules. Examples include:

• Our overview of REACH, RoHS & POPs and how they interact with CLP.
• Product-specific legislation (detergents, cosmetics, biocides etc.) may impose extra labelling or notification obligations.
• National laws and EU frameworks (such as the EU Safety Gate registration) require supply-chain vigilance.
  
  

6. Key updates and where to watch

Because the regulatory environment evolves, it’s vital to monitor updates:

• Adaptations to Technical Progress (ATPs) amend classification criteria and hazard statements.
• The harmonised PCN format (Annex VIII) became fully mandatory by January 2025.
• Recent e-learning options include:
• CLP Hub – EU CLP Labelling & Packaging
• CLP-EU Training Portal
• Chemical Business Association – CLP Training
• Chemical Watch – Introduction to the CLP Regulations
• ECHA Training Materials on CLP

Tip for compliance: Even if your formulation doesn’t change, classification criteria might, so periodically review your labels, SDS and notification status.

7. What it means for your business (implications)

As a manufacturer or importer of substances or mixtures for the EU, you must ensure:

• You have accurate hazard data and classification decisions.
• You produce compliant labels and packaging.
• You communicate hazard information to downstream users and distributors.
• For mixtures classified as hazardous: you generate the UFI, notify via PCN, and include this in your SDS and label.
• You monitor legislative updates and adapt accordingly.
• You maintain full documentation (classification justification, labels, SDS, notifications) to demonstrate compliance.

Failing to comply may lead to enforcement action, product withdrawal, reputational damage or safety risks.

8. Practical Steps to Compliance

Here are actionable steps you can take:

1. Assemble hazard data – gather physical, health, environmental hazard info for your substance/mixture.
2. Perform classification using CLP criteria (Annex I etc.).
3. Design label & packaging – ensure hazard pictograms, signal word, H/P-statements, UFI (if needed) and supplier details. For more on labelling under other regimes see our article on labelling requirements under GPSR.
4. Check packaging suitability for the contents – resistant, sealed and durable.
5. Notify if required – submit PCN via ECHA, include the UFI.
6. Review your supply chain – ensure downstream users, importers and distributors have correct SDS and labels.
7. Maintain records – keep SDS, labels, classification justification and notifications organised. Explore our guide on GPSR-technical file documentation for broader product compliance.
8. Monitor changes – stay updated on ATPs, new mixtures, classification shifts and regulatory revisions.
9. If formulation changes – re-classify, re-label, generate new UFI and re-notify as required.
10. Train your team – ensure awareness of CLP obligations, labelling and supply-chain compliance. Consider accredited training courses for chemical safety.
    
    

9. Common Pitfalls & How to Avoid Them

Common errors include:

• Using outdated hazard or test data → leads to inaccurate classification.
• Incomplete labelling (missing pictograms, signal word, supplier info) → non-compliant product placed on market.
• Packaging not suited for contents → breach of packaging requirements.
• Not tracking ATPs and classification changes → labels go out-of-date.
• Neglecting mixture notifications/UFI → missing poison centre information.
• Poor supply-chain communication → downstream users unaware of obligations.
  
  

10. Conclusion

The CLP Regulation (EC 1272/2008) remains foundational to chemical hazard communication in the EU. If you deal with substances or mixtures you must classify, label, package and notify as required. Compliance is neither optional nor static—it demands ongoing attention.

At EaseCert, we support clients with classification decisions, label reviews, UFI/PCN notification, SDS updates and full technical-file preparation. If you'd like help navigating CLP, UFI/PCN or broader chemical compliance see what we offer. We’re glad to assist.

Thank you for reading. Feel free to explore our other resources including our guide on EU compliance guide for selling consumer products and contact us for personalized support.

 

Further Information

• EU Product Safety Legislation – Safety Gate Portal
• Summaries of EU Legislation – General Product Safety Regulation