CLP vs GHS: 7 Key Differences Every Chemical Manufacturer Must Know

The United Nations GHS (Globally Harmonized System) is a model — a menu of hazard classes, categories, pictograms, and phrases. Each jurisdiction picks which GHS "building blocks" it adopts and adds regional requirements. In the European Union, Regulation (EC) No 1272/2008, commonly known as CLP (Classification, Labelling and Packaging), is the legal instrument. It's aligned with GHS but has been amended more than 20 times and includes several EU-specific rules.

Here are the seven differences most likely to trip up a first-time EU exporter.

1. EUH Statements — CLP-Only Supplemental Phrases

GHS uses H (Hazard) and P (Precautionary) statements. CLP adds a separate class: EUH statements, prefixed "EUH". These describe hazards not covered by UN GHS but relevant to EU consumers or workers.

Examples:

• EUH014 — Reacts violently with water.
• EUH059 — Hazardous to the ozone layer.
• EUH066 — Repeated exposure may cause skin dryness or cracking.
• EUH070 — Toxic by eye contact.
• EUH208 — Contains <name of sensitizing substance>. May produce an allergic reaction.
• EUH210 — Safety data sheet available on request.

EUH208 and EUH210 alone appear on the majority of mixture labels sold in the EU. UN GHS has no equivalent.

2. Harmonized Classification (CLH) — Annex VI Overrides Self-Classification

Under UN GHS, classification is done by the supplier (self-classification). In the EU, certain substances have a legally binding harmonized classification listed in Annex VI of CLP. If a substance appears there, you must use the Annex VI classification even if your own test data suggests otherwise (though you may add additional classifications where Annex VI does not cover a specific endpoint).

As of the 21st ATP (Adaptation to Technical Progress), Annex VI contains over 4,500 harmonized entries — mostly CMR (carcinogens, mutagens, reproductive toxins) and respiratory sensitizers.

3. Poison Centre Notification (PCN) and the UFI

Since 1 January 2021 for consumer products (and 1 January 2024 for industrial), any hazardous mixture placed on the EU market must be notified to national poison centres via the ECHA PCN portal. Each notification is linked to a Unique Formula Identifier (UFI) — a 16-character alphanumeric code that must appear on the label.

This has no UN GHS counterpart. If you sell into the EU and the mixture is classified for health or physical hazards, no UFI on the label = illegal placement on the market.

4. Child-Resistant Fastenings and Tactile Warnings

CLP Article 35 and Annex II Part 3 require:

• Child-Resistant Fastenings (CRF) for consumer packaging containing substances classified as acute toxicity Cat. 1-3, STOT SE/RE Cat. 1, skin corrosion Cat. 1, or specific sensitizers/aspiration hazards.
• Tactile Warnings for Danger (TWD) — a raised triangle on the closure — for consumer packaging where the mixture is classified for acute toxicity, skin corrosion, germ cell mutagenicity Cat. 2, carcinogenicity Cat. 2, reproductive toxicity Cat. 2, respiratory sensitization Cat. 1, STOT, aspiration, or flammable Cat. 1-2.

UN GHS mentions "means for tactile warning" as a possibility, but does not mandate CRF/TWD. This is a purely EU add-on.

5. Fold-Out Labels and Language Requirements

CLP requires the label to be in the official language(s) of the Member State where the product is sold. A product sold in Belgium, for example, may need Dutch, French, and German. To fit multiple languages, CLP explicitly permits fold-out labels (also called "concertina" or "booklet" labels) — as long as the outer face still displays product identifiers and pictograms.

GHS at the UN level is language-neutral and makes no such provision.

6. Selective Adoption of GHS Categories ("Building Blocks")

CLP does not adopt every GHS category. Notable gaps:

• Flammable liquids Cat. 4 (flashpoint 60-93°C) — used in some jurisdictions but not classified in CLP; instead handled via other legislation (e.g., transport ADR).
• Acute toxicity Cat. 5 — GHS defines this low-toxicity category, but CLP does not implement it.
• Skin/eye irritation Cat. 3 (mild irritant) — GHS optional, not adopted by CLP.

If your SDS was written for a non-EU market, do not blindly copy Cat. 4/5 classifications — they don't translate.

7. Labeling of Small Packages (Consumer)

CLP Article 29 and Annex I Section 1.5 allow reduced labeling for very small packages (≤125 mL) or where the shape/nature makes a full label impossible. Certain hazard categories may waive H-statements or precautionary statements, but the signal word and pictogram cannot be omitted for the highest-hazard categories.

UN GHS has general guidance but leaves waiver thresholds to competent authorities. CLP's rules are prescriptive and enforceable.

Quick Comparison Table

What This Means Practically

If you already have a compliant GHS label and SDS for another market (say, US or China), you will still need to:

1. Re-check classification against CLP Annex VI.
2. Remove any Cat. 4 flammable / Cat. 5 acute tox classifications.
3. Add applicable EUH statements (especially EUH208, EUH210, EUH066 for common irritants).
4. Register the mixture through the ECHA PCN portal and generate a UFI.
5. Add CRF and TWD to consumer packaging where thresholds are met.
6. Translate the label into all required Member State languages.

Related Tools

• CLP H/P/EUH Phrase Lookup — searchable database of every phrase with EU-approved wording.
• GHS Label Generator — build a bilingual label with pictograms.
• SDS 16-Section Template — CLP-aligned Safety Data Sheet starter.
• GHS Pictogram Pack (SVG)

Sources: Regulation (EC) No 1272/2008 (consolidated version, latest ATP), UN GHS Rev. 10 (2023), ECHA Guidance on labelling and packaging.