An attempt to develop a universal system for labeling hazardous substances and
The UN GHS is not a formal treaty, but instead is a non-legally binding international
agreement. Therefore countries (or trading
blocks, like the European Union) must establish legislation for their jurisdiction in
order to implement the UN GHS.
The GHS is being implemented in the EU via the Regulation on Classification, Labelling
and Packaging of Substances and Mixtures (known as the CLP Regulation).
The CLP isn’t only about labelling. As it’s name makes clear, there are also
requirements relating to how the substances are packaged.
As a Regulation, it is directly-acting in all EU Member States, requiring no national
transposition. Its provisions will be phased in over a period of years until 1 June 2015
when the Regulation will be fully in force.
The new labelling requirements have some similarities, but a number of differences,
to the those we’re used to in Europe.
Labels on the packaging of hazardous substances and preparations (i.e. mixtures of
chemicals) will still have to show pictograms which summarise the key hazards, but
they will look different
New pictograms are introduced that replace the old CHIP orange rectangles
Most of the symbols used are the same, although there are some new ones
The format of the pictograms is based on those currently used for the transport of
Dangerous Goods under the “Accord européen relatif au transport international des
marchandises dangereuses par route”, known as ADR, which implemented another
UN agreement in Europe
Acute toxicity (Classes 1 to 3)
The familiar terms “very toxic” and “toxic” will no longer be used. Instead Hazard
categories are applied – the lower the category the more hazardous the material
The familiar St Andrews cross will be replaced by the new “exclamation mark
symbol”. It will be applied to irritant substances and category 4 acute toxicity.
However, some substances currently carrying the cross will have to show the new
“skull and crossbones” symbol due to new rules on classification.
I think many people will find this confusing. It doesn’t have an obvious meaning.
This new pictogram is applied to substances that present serious longer term health
hazards such as carcinogens and respiratory sensitisers
For each type of hazard there are a number of hazard categories
The number of hazard categories varies depending on the hazard
The lower the number, the greater the hazard
New criteria are introduced for assigning the hazard class.
This is likely to have some significant implications for suppliers as there are some
significant differences between the system used under CHIP and the new CLP
Annex VII of the CLP Regulation presents a ‘translation’ table which can be used to
‘convert’ classifications made under the current Dangerous Substances Directive to
the new classifications made by applying the CLP criteria. Where there is no direct
one-to-one equivalent, the Annex has assigned the least severe classification and
places a duty on the supplier to decide if a more severe classification is needed. This
annex is intended to be used by those substances and mixtures that have already
been self-classified under the existing European legislation, and where the hazard
categories identified are equivalent.
One of these two signal words will have to be printed on the label. In effect they take
the place of the CHIP hazard category statements (e.g. Toxic, Irritant, Corrosive etc.)
Which signal word is used depends on the hazard category
Sometimes labels may also include information required under the ADR (i.e. for
There are no plans to provided any guidance on CLP at UK level. The HSE refers
chemical suppliers (and anyone else who want more information) to the European
Chemicals Agency (ECHA) guidance available at
Manufacturers and importers need to notify ECHA by 3 January 2011 of the
classification of substances placed on the market that are:
- subject to REACH Registration (for substances to be registered by 30 November
2010, notification will be part of the registration dossier);
- classified as hazardous (regardless of volume)
- in mixtures above certain concentration limits, which result in the need for