CLP Labelling and COSHH: How They Connect

What Is the CLP Regulation? (Short Answer)

CLP — Classification, Labelling and Packaging — is the regulation that decides how chemicals are classified for hazard, what goes on the label, and how they are packaged. It is the source of the red-bordered diamond pictograms, the signal words "Danger" and "Warning", and the H-phrases on every container in your store.

CLP is a supplier regulation. It tells manufacturers, importers and distributors how to classify and label what they sell. COSHH is an employer regulation — it tells you what to do with those chemicals once they are in your workplace.

The two are joined at a point most guidance skips: COSHH defines its own scope by reference to CLP. Whether a substance is "hazardous to health" for COSHH purposes is settled by CLP classification criteria. Get the CLP reading wrong and the COSHH assessment starts from the wrong place.

GB CLP and EU CLP Since 2021

Since 1 January 2021 there have been two regimes, and which one applies depends on where the chemical is placed on the market.

Great Britain (England, Scotland, Wales). HSE's guidance on classification, labelling and packaging of chemicals in GB or NI states:

"the classification, labelling and packaging of chemicals placed on the market in Great Britain (England, Scotland and Wales) is regulated by the 'Assimilated CLP Regulation (EU) No. 1272/2008 as amended for Great Britain', known as GB CLP."

Northern Ireland stays on the EU regime. The same HSE page continues:

"The classification of chemicals placed on the market in Northern Ireland is regulated by a European regulation known as EU CLP under the Northern Ireland Protocol and the Windsor Framework."

The other structural change is who runs it. HSE's guidance again:

"The Health and Safety Executive (HSE) is the GB CLP Agency and carries out certain CLP functions previously undertaken by the European Chemicals Agency (ECHA)."

For most employers this is background rather than a duty. It matters in two practical situations: if you supply chemicals as well as use them, and if you buy from an EU supplier whose labelling was prepared for the EU market. HSE is clear the core obligations did not change — "the main duties to classify, label and package remain."

Since the two regimes can diverge over time, a substance's GB classification and its EU classification will not necessarily stay identical. If you rely on a supplier's classification, it is worth knowing which market it was prepared for.

The Link Most Guides Miss

Here is the provision that ties the two regulations together. COSHH regulation 2(1) defines "substance hazardous to health" as a substance (including a mixture):

"(a) which meets the criteria for classification as hazardous within any health hazard class as provided for in the CLP Regulation whether or not the substance is classified under that Regulation;"

Read that final clause again — "whether or not the substance is classified under that Regulation".

This is the sentence that catches people out. COSHH does not ask whether your supplier put a label on it. It asks whether the substance meets the criteria. So:

An unlabelled product, or one supplied in a plain container, is still within COSHH if it meets the criteria.
A substance your process generates — wood dust, welding fume, flour dust, silica — never gets a supplier label at all, and is still squarely within scope.
A supplier's failure or omission to classify does not narrow your duties by one inch.

"There was no hazard label on it" is not a COSHH defence.

The definition then extends beyond CLP entirely, picking up substances with an HSE-approved workplace exposure limit, biological agents, and dust of any kind at or above "10 mg/m³, as a time-weighted average over an 8-hour period, of inhalable dust" or "4 mg/m³ ... of respirable dust". There is also a catch-all at (e) for anything that, "because of its chemical or toxicological properties and the way it is used or is present at the workplace creates a risk to health."

Between them, those five limbs are why what is covered by COSHH is a wider net than a shelf-scan of hazard labels would suggest.

Only Health Hazard Classes Count

A detail worth holding onto, because it cuts both ways.

CLP sorts hazards into four families, set out as Parts 2 to 5 of Annex I: physical hazards (flammable, explosive, oxidising), health hazards (acute toxicity, corrosion, sensitisation, carcinogenicity and so on), environmental hazards, and additional hazards (for example hazardous to the ozone layer). COSHH regulation 2(1)(a) picks up only "any health hazard class".

So a product classified solely as flammable, with no health hazard class, is not brought into COSHH by that classification alone. That does not make it safe or unregulated — flammability is dealt with under DSEAR, and the substance may still enter COSHH through one of the other limbs of the definition, such as an approved exposure limit. But the CLP pictogram on the drum is not, by itself, the COSHH trigger people assume it is.

The corollary is more important: a substance with a health hazard classification is in scope, even if it looks innocuous and lives under a sink.

Reading the Label

A compliant GB CLP label carries the supplier's name, address and telephone number, the product identifier, and — where applicable — hazard pictograms, a signal word, hazard statements (H-phrases), precautionary statements (P-phrases) and a section for supplemental information. Article 17(1) sets that list.

The nominal quantity is on the list too, but conditionally. Article 17(1)(b) requires "the nominal quantity of the substance or mixture in the package made available to the general public, unless this quantity is specified elsewhere on the package" — so a trade-supplied drum with no quantity on the hazard label is not non-compliant for that reason alone.

For your assessment, the H-phrases do the heavy lifting — they are the specific hazard, where the pictogram is only the family. H334 ("may cause allergy or asthma symptoms or breathing difficulties if inhaled") tells you that you are dealing with a respiratory sensitiser and pulls in a whole set of duties that a generic "harmful" reading would miss. Our guides to COSHH symbols and GHS hazard labels and occupational asthma go into both.

If you have a label in front of you and want its health H-codes decoded quickly, our free GHS hazard label decoder does that.

The label is a summary. The full classification detail lives in Sections 2 and 3 of the safety data sheet — see how to read an SDS.

Supplier Duties vs Your Duties

Keeping these separate saves a lot of confusion:

	CLP (supplier)	COSHH (employer)
Who it binds	Manufacturers, importers, downstream users, distributors placing chemicals on the market	Employers whose work exposes people to hazardous substances
Core obligation	Classify, label, package correctly	Assess the risk; prevent or adequately control exposure
Applies to process-generated substances?	No — no supplier, no label	Yes
Regulator	HSE as GB CLP Agency	HSE / local authority as enforcing authority

If you decant a chemical into a smaller container for use in your workplace, you are not "placing it on the market", so CLP supplier labelling duties are not what bites — but you still have COSHH duties around identification and safe use, and an unlabelled decanted container is a recurring inspection finding. Labelling it with the product name and hazard information is the practical answer.

The full set of employer obligations is set out in the COSHH Regulations 2002.

CLP and COSHH Checklist

You know whether you place chemicals on the GB market (supplier duties) or only use them (employer duties)
Labels checked for the GB market where relevant, not only EU labelling
H-phrases — not just pictograms — recorded in your assessments
H334 and other sensitiser statements flagged for health surveillance
Process-generated substances assessed despite having no label
Unlabelled and decanted containers identified and labelled
Substances with an approved exposure limit captured even where no CLP health classification applies
Dust assessed against the 10 mg/m³ inhalable and 4 mg/m³ respirable thresholds
Safety data sheets on file for every commercial product

From Label to Assessment

The gap between a shelf of labelled containers and a defensible set of COSHH assessments is mostly transcription — pulling the right H-phrases off the right products and turning them into controls, exposure checks and surveillance triggers, then keeping that current as products change.

COSHHmate is being built to carry the classification through to the assessment, so the hazard information you record once drives the controls and the review dates that follow from it. Pricing will be a flat monthly fee with no per-user charges. To get your chemical inventory working properly, join the waitlist.

Sources

This is general guidance based on the COSHH Regulations 2002, the assimilated GB CLP Regulation and published HSE guidance. GB and EU CLP can diverge over time, and Northern Ireland follows EU CLP — check the current position with HSE, or take advice from a qualified chemical regulatory specialist, for your specific products. Not legal advice.