What is the Classification, Labelling and Packaging (CLP) Regulation?
Oct 18, 2022
The Classification, Labelling and Packaging (CLP) Regulations 1272/2008 is the legislation that is used in the European Union (EU) for the classification and labelling of substances and mixtures. The CLP is legally binding across the Member States, and it requires manufacturers and importers of substances/mixtures to classify, label and package their hazardous chemicals properly before allowing them to go on to the market. 

The CLP sets detailed instructions for the labelling elements such as pictograms, signal words and statements for hazard, prevention, response, storage, and disposal. It also sets general packaging standards to ensure the safe supply of hazardous substances and mixtures. The CLP is also the legislation that sets out the more recent requirements of needing unique formula identifiers (UFI) and Poison Centre notifications (PCN), especially for vape products containing any liquid or formulation.

Classification, Labelling and Packaging (CLP) in relation to vape products

Within the CLP there are many articles relating to the packaging, labelling and layout of products classified as hazardous such as e-liquids, pods, or disposables. This is important when making the packaging for your product, as you need to be aware of requirements such as ensuring the pictograms, signal word, hazard statements and precautionary statements are all grouped and located together on the packaging and label. This is to ensure you are complying with the law and that your packaging and label is laid out logically and in a way that is easily understood by consumers. 

Why is a Safety Data Sheet (SDS) relevant to Classification, Labelling and Packaging (CLP)?

The CLP also relates to Safety Data Sheets (SDS). These are important to have when dealing with mixtures and substances and are required to be uploaded for a PCN when launching a product in an EU country. Your SDS is where you will get your information for your label in terms of what pictogram you should use, the hazard and precautionary statements that need to be included and the appropriate signal word. This classification is made using the ingredients and their specific quantities, and therefore will directly apply to your product, this is mainly dependent on nicotine strength to decide which pictogram and other hazard elements are needed on the packaging and labelling.

What is an Adaptation to Technical and Scientific Progress (ATP)?

The CLP introduces updates quite regularly. This is not for the overall regulation, but for the Annexes. These updates are made through adaptions to technical and scientific progress (ATP). An ATP brings changes to the classification and labelling of some of the already existing harmonised substances and can also include new substances which will be harmonised throughout the member states and become part of the regulation. This is issued yearly by the European Commission, where they get the opinions of the Committee for Risk Assessment (RAC) based on the classification and labelling of certain substances. After these opinions have been collated, the European Commission will make a decision and publish it in the new ATP list. We are currently on CLP ATP 17 but there is an update coming into force in November 2023 titled CLP ATP 18. Therefore, it is important to keep a look out for these changes when creating the likes of a Safety Data Sheet.

We can help

At Inter Scientific, we have experience dealing with this legislation and the multiple aspects within it. Therefore, we would be able to help you with the likes of packaging reviews to make sure your packaging and labels are in line with the requirements of the CLP and suitable for the notification process covered by the Tobacco Products Directive. Inter Scientific also has the ability to create Safety Data Sheets, with extensive training and the appropriate software systems allowing us to create a SDS based on your information and ingredients that is in line with the CLP and REACH regulations. Ready to benefit from our expertise? Contact us today!

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