What is CLP? CLP Regulation, Pictograms and Labeling

What is CLP?

CLP (Classification, Labeling and Packaging) is the European Union's (EC) No 1272/2008 Classification, Labeling and Packaging Regulation. How to classify chemicals and mixtures according to their physical, health and environmental hazards; It determines which pictogram, signal word, H and P statements will appear on the label. Its equivalent in Turkey is SEA Regulation.

The Regulation came into force in 2009 and replaced the former Dangerous Substances and Dangerous Preparations directives in the EU. The orange square symbols (letter coded signs such as valid today are rhombus pictograms with red frames. If you still see an orange square on a label you have, that label has not been prepared in accordance with current legislation.

CLP covers three connected tasks. First, classification determines a product’s hazard classes and categories. Second, hazard communication conveys that classification on the label and in the safety data sheet using standard wording. Third, packaging must withstand its contents and, where required, include child-resistant fastenings and tactile warnings. An annex also contains the list of harmonised classifications that are binding across the EU for certain substances. This list is periodically updated through adaptations to technical progress (ATPs).

Difference between CLP, SEA and GHS

The three abbreviations are often used interchangeably, although they are at different levels. GHS is the global framework proposed by the United Nations; CLP is the binding form of this framework in the EU; SEA is the equivalent of CLP in Turkey.

The practical consequence is that a US or Asian label that says “GHS compliant” is not automatically suitable for Türkiye. A CLP label issued in the EU is much closer, but copying it directly is risky. It should also be checked which version of the harmonized list is taken as basis, component-specific limits and the official Turkish texts of the H/P statements; Not every change that comes into force in the EU is reflected in SEA at the same time. We check these differences in products released to the Turkish market, starting from the formulation within the scope of our SEA regulation service.

Hazard classes in CLP

CLP groups hazards into three main groups. Within each group there are hazard classes, and within each class there are categories showing the degree of severity. Everything written on the label derives from this class and category decision.

The EU added new hazard classes to CLP for endocrine disruptors, PBT/vPvB and PMT/vPvM in 2023. How and on what schedule these classes will be transferred to SEA should also be monitored; For companies exporting to the EU, the change is reflected in the content of the label and safety data sheet with a gradual transition schedule.

9 hazard pictograms (GHS01–GHS09)

Hazard pictograms — known in the legislation as hazard pictograms — are red-framed rhombuses with a black symbol on a white background. There are a total of nine pictograms in CLP and SEA, each referred to by their GHS code:

Pictograms are not added freely; There are priority rules. If GHS06 is assigned to the product, no additional GHS07 is assigned for acute toxicity. If GHS05 is used for skin corrosion or serious eye damage, GHS07 for skin or eye irritation is not added. If GHS08 is present for respiratory sensitization, GHS07 is not used for skin sensitization or irritation. An unnecessary pictogram is considered as non-conformity as a missing pictogram. In CLP, each pictogram is required to be at least one fifteenth of the label surface and at least 1 cm².

Signal words: “Danger” and “Caution”

The warning word informs the reader of the severity of the hazard in a single word. There are two options: Danger is used for heavier categories, Caution is used for lighter categories. A few examples clarify the difference:

The rule is simple but frequently broken: there is only one signal word on the label. If the product falls into both Danger and Caution classes, only “Danger” is written. In some environmental categories, the warning word is not used at all. The words "Danger" and "Warning" on English labels must be translated into Turkish on the product placed on the market in Turkey.

H and P expressions

H statements (hazard statements) describe the damage that the product may cause in standard sentences. The first digit of the code indicates the group: 2 physical, 3 health, 4 environmental hazards. For example, H225 “Easily flammable liquid and vapour.”, H314 “Causes severe skin burns and eye damage.”, H410 “Very toxic in the aquatic environment with long-lasting effects.” means. H expressions are not selected; It is a direct result of classification. CLP also provides some additional information with EUH codes that have no equivalent in the GHS; for example, EUH208, which is used in mixtures that contain a sensitizing ingredient but are not classified.

P statements (precautionary statements) tell what to do for protection and are grouped in five groups: P1xx general, P2xx prevention, P3xx intervention, P4xx storage, P5xx disposal. Combined expressions such as P280 indicate the use of protective gloves and eye protection, and P305+P351+P338 describes what to do in case of eye contact. Unlike H statements, P statements are selected: as a rule, it is expected that there will be no more than six precautionary statements on the label, so prioritization is made according to the actual use of the product.

In both types of expressions, the texts must be written verbatim, with their official Turkish equivalents in the legislation; Even if the meaning is correct, free translation is considered inappropriate. For details of the class–category–expression relationship, you can refer to our hazard classes and H phrases guide.

What should be on the label? CLP label elements

The label of a product classified as harmful is a summary of the classification on the packaging. A SEA/CLP compliant label includes the following elements:

• Supplier information — name, address and telephone number of the company that supplies the product to the market
• Nominal quantity — in publicly available packaging
• Product identifier — trade names and names of ingredients in mixtures that contribute to the hazard
• Hazard pictograms
• Signal word — Danger or Caution
• H expressions and P expressions
• Additional information — EUH statements, if any; UFI code when necessary for harmful mixtures

The label on the product placed on the market in Turkey must be Turkish; Multilingual labels are accepted as long as the mandatory information remains complete and legible. The most common deficiencies in the audit - thinly printed red frame, supplier field left with the address of the foreign manufacturer, incorrect use of the small packaging exception - are explained in detail in our common mistakes in labels and packaging article. For ready-to-print label text, you can review our labeling and packaging consultancy page.

How are mixtures classified?

The classification of a single substance is often read from the harmonized list or registration data. In mixtures, the decision is made in a certain order; It is only possible to move on to a lower step when the upper one does not yield results:

1. Test data of the mixture itself — if there is suitable data for the entire mixture, it is used first.
2. Bridging principles — if there is a similar mixture tested (dilution, different batch, concentration change) the conclusion is drawn based on it.
3. Calculation from component data — classes and proportions of components are combined with general concentration limits and addition rules.

The most frequently overlooked point in the calculation is the specific concentration limits defined for some components and the M-coefficients in environmental hazards. These replace global thresholds; If overlooked, the mixture appears “harmless”, which should be classified due to a low concentration of a potent ingredient. Details of the steps are in our articles Calculation method in mixture classification and Correct approach in SEA (CLP) classification.

SDS and UFI relationship with CLP

Taxonomy does not stop at a single document; It feeds three separate outputs, and all three must be exactly consistent with each other:

• Safety data sheet (SDS). Classification and labeling elements are entered in the 2nd part of the form (Hazard identification), ingredient information is entered in the 3rd part. Non-compliance with H statements on the label and section 2 is the most frequently detected non-conformity in the audit. Detail: Safety Data Sheet (SDS) preparation; What is MSDS? for questions about the common name of the document; sample of safety data sheet to see what the form looks like.
• UFI code and PCN notification. In mixtures classified in terms of health or physical hazard, a 16-character UFI code is generated, reported to the poison control center and printed on the label. Only mixtures that pose environmental hazards are excluded from this obligation. Detail: UFI code generation and tag compliance.
• Label. All the above elements are derived from the same classification.

Even a small change in formulation can therefore require the whole chain to be reviewed: classification is recalculated, the SDS and label are updated, and a new UFI is generated where necessary. In Türkiye, safety data sheets must be prepared by a Chemical Assessment Expert (KDU), so this work is carried out under KDU supervision.

Frequently asked questions

What does CLP mean?

CLP is the abbreviation of the English expression Classification, Labeling and Packaging and describes the Classification, Labeling and Packaging Regulation of the European Union (EC) No 1272/2008. It regulates the hazard classification of chemicals and how this classification will be reflected on the label.

Is CLP regulation the same as CLP?

The logic and classification criteria are largely the same; SEA is the equivalent of CLP in Turkey. However, it is a separate national regulation: the label language is Turkish, the implementing authority is the Ministry and every change made to CLP in the EU is not reflected in the CLP at the same time.

How many hazard pictograms are there?

Nine hazard pictograms are used in CLP and SEA: GHS01 exploding bomb, GHS02 flame, GHS03 flame on circle, GHS04 gas cylinder, GHS05 corrosion, GHS06 skull, GHS07 exclamation mark, GHS08 health hazard and GHS09 environment.

What is the difference between Danger and Caution?

Both are signal words. Danger, for more severe hazard categories; Caution is used for lighter categories. There is only one on the label: Caution is omitted if the product is classified as Dangerous.

Who does the CLP classification?

The obligation to classify belongs to the manufacturer or importer who places the product on the market; subusers who prepare mixtures also classify their own products. Since the safety data sheet must be prepared by a Chemical Evaluation Expert (KDU) in Turkey, the classification is carried out in practice under the supervision of the KDU.

Are GHS pictograms and CLP pictograms different?

The symbols are the same; CLP uses nine pictograms of GHS. The difference is in the categories: the EU has not included some mild categories in the GHS (e.g. category 5 of acute toxicity) in CLP. For this reason, the GHS label prepared for another country cannot be used directly in Turkey.

What is the difference between H expression and P expression?

H (hazards) indicates which hazard the product causes, for example H225 Highly flammable liquid and vapour. The P (precaution) statement tells you what to do to prevent this harm, for example P210 or P280. H expressions derive directly from classification; P expressions are selected according to this classification.

Definition of all KKDIK and chemical regulations terms: KKDIK Glossary of Terms