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19 April 2025

10 Common Mistakes on CLP Labels (and How to Avoid Them)

1. Treating the label solely as a marketing tool

Catchy slogans, vivid colours and eye-catching graphics are welcome—but they must not overshadow what matters most: the mandatory CLP label elements.

Adding more marketing content does not justify omitting hazard information due to “lack of space.”

Before placing a chemical product on the market, make sure your label includes:

  • Hazard (H) and precautionary (P) statements,

  • GHS hazard pictograms,

  • Product and supplier identification.

All this information is available in the Safety Data Sheet (SDS).

2. Black-and-white or empty GHS pictograms

Black-and-white pictograms are only allowed in specific cases, such as transport. For products sold to consumers, labels must include coloured GHS pictograms with a red border.

It is also forbidden to use “empty” pictograms—i.e. red diamonds without the black hazard symbol inside.

3. Font size too small

If the text on the label cannot be read from 20–30 cm away, the font is too small. A font size of at least 6 pt is generally considered readable, especially for hazard-related text.

Of course, following the recent updates to the CLP Regulation, new minimum font size requirements will apply—make sure you comply with the current version.

4. GHS pictograms too small

Pictograms are not decorative—they have specific size requirements.

✅ For packaging up to 3 litres: minimum 10 x 10 mm

✅ For packaging between 3–50 litres: minimum 23 x 23 mm

5. Horizontally oriented text on a vertically displayed product

The label must be legible without having to rotate the package. Ensure that the content is printed horizontally in relation to how the product stands on the shelf.

6. Different product names on the label and in the SDS

A creative marketing name is fine—but it must match exactly between the CLP label and the Safety Data Sheet. Any discrepancy causes confusion and may lead to non-compliance.

7. No translation of hazardous substance names

Whether selling locally or internationally, the names of hazardous substances must appear in the official language(s) of the country where the product is marketed. English alone is not sufficient.

8. Missing contact details of the supplier

Under CLP, the label must include the name, address and telephone number of the responsible party—whether it’s the manufacturer, importer or distributor.

9. Outdated label after a change in composition or classification

Any change in the composition or classification of a mixture requires an update of both the CLP label and the Safety Data Sheet. This is not optional—it’s a legal obligation.

10. Missing UFI number for mixtures notified to the PCN portal

If your mixture has been notified under Article 45 of the CLP Regulation via the Poison Centre Notification (PCN) portal, the UFI (Unique Formula Identifier) must be included on the label.Omitting it is a frequent but serious compliance error.

Summary – How to avoid CLP label mistakes?

  • Always verify that label content matches the Safety Data Sheet.

  • Stay up to date with changes to the CLP and REACH regulations.

  • Test label readability on actual packaging.

  • Never treat legal label elements as "nice-to-haves"—they are essential for compliance and safety.

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