CLP Labeling: Requirements, Elements, and Automatic Label Generation

Mandatory Elements of the CLP Label (Art. 17)

Article 17 of the CLP Regulation defines the elements that must appear on the label of any substance or mixture classified as hazardous. The label must be firmly affixed to one or more sides of the packaging in direct contact with the contents and must be legible horizontally when the packaging is in its normal position. The mandatory elements are:

• Product identifier — Name of the substance (IUPAC name, common name) or mixture identifier (trade name and identity of all substances contributing to the classification)
• Supplier details — Name, address, and telephone number of the manufacturer, importer, or distributor responsible for placing the product on the market
• Nominal quantity — Volume or mass of the contents for packaging intended for the general public
• Hazard pictograms — GHS/CLP symbols on a white background with a red diamond-shaped border, in accordance with Annex V of the CLP
• Warning — "Danger" (for the most serious categories) or "Caution" (for the less serious categories)
• Hazard statements (H phrases) — Describe the nature and degree of the hazard
• Precautionary statements (P phrases) — Indicate recommended measures to prevent or reduce harmful effects
• Supplementary information — EUH statements, tactile hazard information, and other elements required by the legislation

kemXpro automatically compiles all these elements based on the classification of the substance or mixture, ensuring consistency between the Safety Data Sheet (SDS) and the label.

Label and Pictogram Dimensions (Art. 31)

Article 31 of the CLP and Table 1.3 of Annex I establish the minimum dimensions of the label and pictograms according to the capacity of the packaging. Failure to comply with these dimensions constitutes a punishable non-compliance:

• Capacity ≤ 3 liters — Minimum label 52 x 74 mm; minimum pictogram 16 x 16 mm (side of the diamond not less than 16 mm)
• Capacity > 3 liters and ≤ 50 liters — Minimum label 74 x 105 mm; minimum pictogram 23 x 23 mm
• Capacity > 50 liters and ≤ 500 liters — Minimum label 105 x 148 mm; minimum pictogram 32 x 32 mm
• Capacity > 500 liters — Minimum label 148 x 210 mm; minimum pictogram 46 x 46 mm

kemXpro automatically selects the correct label format based on the configured packaging volume, resizing pictograms and layouts to meet minimum requirements. Templates are fully customizable to fit your corporate design while maintaining regulatory compliance.

Pictogram Precedence Rules (Art. 26 CLP)

Article 26 of the CLP Regulation defines precedence rules that determine which pictograms must appear on the label when a substance or mixture presents multiple hazards. These rules avoid redundancy and ensure that the most serious hazards are communicated:

• GHS06 (skull and crossbones) replaces GHS07 (exclamation mark) — If the substance is classified as acute toxicity Cat. 1-3, the GHS07 pictogram for acute toxicity Cat. 4 must not appear
• GHS05 (corrosion) replaces GHS07 for skin and eye irritation — If the substance is corrosive (Skin Corr. 1), the exclamation mark for skin or eye irritation is redundant
• GHS08 (health hazard) with respiratory sensitization replaces GHS07 for skin sensitization — Respiratory sensitization (Resp. Sens. 1) takes precedence
• GHS02 (flame) or GHS01 (exploding bomb) make GHS04 (gas cylinder) optional for flammable gases — If the gas is flammable, the cylinder pictogram can be omitted

kemXpro automatically applies these precedence rules during label generation, eliminating redundant pictograms and producing a compliant label without manual intervention.

Warnings: "Danger" and "Warning"

The CLP provides for two signal words: "Danger" for the most serious hazard categories and "Warning" for the less serious categories. The fundamental rule is that only one signal word may appear on the label. If the classification involves both "Danger" and "Warning," "Danger" always takes precedence. kemXpro manages this logic automatically: simply enter the complete classification and the system selects the correct signal word.

Sorting and Selection of H and P Phrases

Hazard statements (H phrases)

H phrases (Hazard statements) must be printed in full on the label, without abbreviations or modifications to the official text. The order of presentation follows the logic of the classification:

• Physical hazards (H200-H290) — Explosives, flammable gases, aerosols, flammable liquids, flammable solids, etc.
• Health hazards (H300-H373) — Acute toxicity, skin corrosion/irritation, eye damage, sensitization, mutagenicity, carcinogenicity, reproductive toxicity, STOT, aspiration
• Environmental hazards (H400-H420) — Acute and chronic aquatic toxicity, ozone layer hazard

Combined H phrases (e.g., H300+H310+H330) must be reported as a single text. kemXpro manages the entire catalog of H phrases, including combinations, with official texts in all EU languages.

Precautionary statements (P phrases) and the limit of 6

Article 22 of the CLP stipulates that no more than 6 precautionary statements should appear on the label, unless they are necessary to reflect the nature and severity of the hazards. This limitation requires careful selection:

• Selection criteria — Give priority to P phrases relating to the most serious hazards; eliminate redundancies
• Combined P-phrases — Combined phrases (e.g., P301+P310) count as a single P-phrase, optimizing space
• P-general, P-prevention, P-response, P-storage, P-disposal — Balance the categories to provide comprehensive information
• Context of use — Consider whether the product is intended for the general public or professional users

kemXpro automatically suggests the optimal selection of P phrases based on classification, respecting the limit of 6 and prioritizing the most significant hazards. The operator can always customize the selection before printing.

UFI code on the label (Annex VIII)

The UFI (Unique Formula Identifier) code is a 16-character alphanumeric code that must appear on the label of mixtures that are hazardous to health or have physical effects, as established by Annex VIII of the CLP. The UFI code allows Poison Control Centers to uniquely identify the exact composition of the mixture in case of emergency.

The UFI code must be preceded by the acronym "UFI:" and be clearly visible, legible, and indelible on the label. kemXpro generates the UFI code in accordance with the ECHA algorithm, associates it with the formulation in the database, and automatically inserts it into the label. Any change in the composition of the mixture generates a new UFI code, ensuring traceability.

Language Requirements and Multi-Country Labeling

Article 17(2) of the CLP stipulates that the label must be written in the official language or languages of the Member State where the substance or mixture is placed on the market. For products sold in multiple Member States, the label must contain the information in all relevant languages.

The challenges of multilingual labeling include:

• Limited physical space — More languages mean more text; the layout must adapt dynamically
• Consistency of translations — H and P phrases have official texts in each EU language that must be used exactly as published
• Handling regional variants — Some languages have variants for different Member States
• Simultaneous updates — A change to the classification must be reflected in all languages

kemXpro natively handles multilingual labeling: the database contains the official translations of all H and P phrases in EU languages. The operator selects the target languages and the system automatically generates the multi-country label with an optimized layout.

Solutions for Small Packaging (Art. 29)

Article 29 of the CLP provides for exemptions for small or specially shaped packaging where it is not possible to affix a complete label in accordance with Art. 31. Permitted solutions include:

• Fold-out labels — These allow the labeling surface to be expanded while maintaining compact external dimensions.
• Tie-on tags — Permitted when the packaging does not allow for direct labeling
• Outer packaging — Full labeling may be affixed to the outer packaging if the inner container is too small
• Exemptions for multiple layers — Some information may be omitted from the inner packaging if it is present on the outer packaging

kemXpro offers specific templates for foldable labels and tags, with automatic calculation of available space and optimal distribution of elements.

Additional Label Elements

EUH statements

EUH statements are additional information specific to the European Union, not covered by the international GHS. They must appear in the additional section of the label and include:

• EUH001 — Explosive when dry
• EUH014 — Reacts violently with water
• EUH029 — Contact with water liberates toxic gas
• EUH031 — Contact with acids liberates toxic gas
• EUH066 — Repeated exposure may cause skin dryness or cracking
• EUH208 — Contains [name of sensitizing substance]. May cause an allergic reaction
• EUH210 — Safety data sheet available on request
• EUH401 — To avoid risks to human health and the environment, follow the instructions for use

Tactile Hazard Warnings (Art. 35 and Annex II, Part 3)

Packaging containing certain hazardous substances or mixtures must be equipped with child-resistant fastenings and/or tactile hazard warnings (raised triangles that can be felt) in accordance with ISO standards. kemXpro automatically flags when a product requires these devices based on its classification.

Automatic Label Generation with kemXpro

kemXpro transforms the entire CLP labeling process into an automated, error-free workflow:

• From classification to label — Enter the composition and kemXpro calculates the classification, pictograms, warning, H/P phrases, UFI code, and generates the label
• Customizable templates — Configurable layouts with company logo, barcodes, QR codes, custom fields, while maintaining CLP compliance
• Batch printing — Simultaneous generation of labels for entire production batches, with PDF, ZPL (for Zebra industrial printers), or image export
• Versioning — Every label revision is tracked: complete history with date, author, and reason for change
• Automatic validation — The system verifies consistency between classification, SDS, and label, reporting discrepancies before printing
• Compliance with Art. 17 and Annex V — Each label generated complies with the dimensional, content, and precedence requirements defined by CLP