The label is the main source of information on the hazards of chemicals that can be accessed by users who may be workers but also consumers.
When is labelling necessary?
Suppliers or importers of a substance or mixture are required to label the product if this product is classified as hazardous. In addition, if a mixture contains at least one substance that is classified as hazardous, the product must be labelled as well.
When it’s difficult to label (because the packaging is designed in such a way that it is not possible to display the labeling elements in accordance with the CLP requirements) or when a substance or a mixture is contained in a packaging that is too small (typically less than 125 ml), the CLP Regulation provides some exemptions (Article 29 and section 1.5.1 o Annex I CLP).
What kind information to include in a label?
Labelling ensures that the characteristics of a given product are clearly visible and accessible. These labels help the user to be aware of any specific hazards as well as necessary precautions which need to be taken when using a product.
According to Article 17 CLP, a substance or a mixture classified as hazardous must bear a label including the following elements:
- Name, address, and telephone number of the supplier(s);
- The nominal quantity of the substance or mixture in the package where this is being made available to the general public, unless this quantity is specified elsewhere on the package;
- Product identifiers;
- Hazard pictograms, where applicable;
- The relevant signal word, where applicable;
- Hazard statements, where applicable;
- Appropriate precautionary statements, where applicable;
- A section for supplemental information, where applicable.
Hazard pictograms are graphical icons that have the purpose to rapidly alert the user of the substance of the hazardous properties of the substance or mixture concerned.
It’s the classification of a substance or mixture that determines the hazard pictograms that have to be displayed on a label (Article 19 CLP).
All pictograms must be presented in the shape of a diamond with a red frame and a black symbol on a white background. The surface area of the pictogram must not be smaller than 1 cm².
For substances and mixtures classified to have more than one hazard, several pictograms may be required on the label. In such cases, the applicability of the principles of precedence set out in Article 26 of the CLP Regulation needs to be consulted. As a general rule, the pictograms which reflect the most severe hazard category of each hazard class must be included on the label.
There are currently 9 different pictograms that are applicable:
Signal words indicate the relative level of severity of a specific hazard. The label must include the relevant signal word in accordance with the classification of the hazardous substance or mixture. More severe hazards require the signal word “Danger” while less severe hazards require the signal word “Warning” (Article 20 CLP).
If a substance or mixture is classified to have more than one hazard with different signal words the label must include only one single signal word. In such cases, the signal word “Danger” takes precedence and the signal word “Warning” must not appear.
Signal words can be found in the tables indicating the label elements required for each hazard class in parts 2 to 5 of annex I CLP.
Hazard statements (H statement)
Hazard statements describe the nature and severity of the hazards of a substance or a mixture (Article 21 CLP).
If a substance or mixture is classified to fall into several hazard classes or differentiations of a hazard class, all hazard statements resulting from the classification must appear on the label, unless there is evidence of a duplication or redundancy (Article 27 CLP).
H statements are codified using a unique alphanumerical code which consists of one letter and three numbers:
- H stands for Hazard statement
o 200 - 299 for physical hazard
o 300 - 399 for health hazard
o 400 - 499 for environmental hazard
Hazard statements and their codes can be found in tables 1.1, 1.2, and 1.3 of Annex III CLP.
Precautionary statements (P statements)
P statements are used to give advice on measures to prevent or minimise adverse effects to human health or the environment arising from the hazards of a substance or mixture (Article 22 CLP).
Normally, not more than six precautionary statements must appear on the label, unless necessary to reflect the nature and the severity of the hazards.
P statements are codified using a unique alphanumerical code which consists of one letter and three numbers:
- P stands for Precautionary statement
o 100 - 199 for general precautionary statements
o 200 - 299 for prevention precautionary statements
o 300 -399 for response precautionary statements
o 400 - 499 for storage precautionary statements
o 500 - 599 for disposal precautionary statements
The complete set of Precautionary statements can be found in the tables indicating the label elements required for each hazard class in parts 2 to 5 of annex I of CLP.
Supplemental labelling information
Article 25 CLP defines the concept of “supplemental information” which is intended to incorporate additional labelling information. This additional labelling information can be divided into two categories, namely obligatory and non-obligatory information.
For a mixture, even if not classified as hazardous, supplemental labelling information might be obligatory on the label (Article 25.6 CLP).
Language of the label
CLP requires the label to be written in the official language or languages of the Member States where the substance or mixture is placed on the market, unless the Member State concerned specifies this obligation differently (Article 17.2 CLP).
Suppliers may accomplish this either by producing multi-language labels covering the official languages of several of the countries where the substance or mixture is supplied to, or by producing separate labels for each country, each with the appropriate language(s).
In Luxembourg, the label must be written in French or in German (Article 4 of Paquet REACH). Information on the required languages of the label for each Member State is accessible in a document made available on ECHA’s website.