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Roles and obligations

A company’s obligations under CLP will depend on their role in the supply chain. The information provided here gives an overview of the roles a company may have and their responsibilities under CLP. All actors in the supply chain have a responsibility to ensure that the hazards of substances and mixtures are identified and communicated to users, including for online sales.

Manufacturer of Substances

A company is a manufacturer under CLP if they are based in the EEA and they produce or extract a chemical substance. Their main obligations under CLP are:

Ensure substances are classified, labelled and packaged according to CLP before they are placed on the market.
Update the label without undue delay if, following an evaluation, the classification and labelling of the substance changes such that a more severe classification applies, or new supplemental label elements are required once they obtain, or are made aware of, the results of the new evaluation.
Where labelling changes other than those described above are required (e.g. where the revised classification will be less severe or the contact details of the supplier have changed), the manufacturer must update the label without undue delay, and in any case, within 18 months.

Where new or updated harmonised classification and labelling arises from a Commission Delegated Act, the act provides for the mandatory application date.

The provision of CLP relating to updating labels was amended by the revised CLP Regulation (Regulation (EU) 2024/2865); however, it is the subject of simplification as part of the Omnibus VI Regulation, which is expected to be published in the Official Journal by the end of 2026. The information provided below is based on the currently applicable CLP Regulation.

Importer of substances/mixtures

A company is an importer under CLP if they are based in the EEA and they import substances or mixtures from outside the EEA (including the UK). Their main obligations under CLP are:

Ensure imported substances and mixtures are classified, labelled and packaged according to CLP before they are placed on the market.

As of July 1^st, 2026, a substance or mixture cannot be placed on the EU market unless a supplier established in the EU, who is identified on the label, fulfils the obligations of CLP in the course of their professional or industrial activity. This applies in particular to products sold on-line and placed on the EU market.

Submit a classification and labelling notification (C&L notification) to ECHA within one month of the first import of a hazardous substance (on its own or in a mixture), irrespective of tonnage, in the following situations:
- The substance is subject to REACH registration; or
- The substance is classified as hazardous; or
- The imported mixture contains a substance that is classified as hazardous at a concentration which results in the classification of the mixture as hazardous; or
- An imported article contains a substance which is subject to registration under REACH.

The obligation to submit a C&L notification does not apply if the information has already been provided as part of a REACH registration.

Submit a poison centre notification (PCN) to the Appointed Bodies where the mixture is placed on the market, if importing a mixture classified as hazardous for human health or physical effects.

In Ireland, the National Poisons Information Centre (NPIC), Beaumont Hospital, is the responsible body appointed for receipt of such information. Companies with questions on the submission process and fees should contact the NPIC (chemicalsinfo@beaumont.ie).

Downstream user, including mixture formulator

A company is a downstream user under CLP if they are based in the EEA and they source their substances or mixtures from a supplier also established in the EEA, and they use those chemicals in their industrial or professional activities. Such activities can include blending them into new formulations and supplying them further down the supply chain or directly to consumers (formulators), using them in processes such as cleaning and lubricating or in services such as dry cleaning, car repair and painting. Their main obligations under CLP are:

Formulators must classify, label and package their hazardous mixtures before they place them on the market.
Formulators must submit a poison centre notification (PCN) to the Appointed Bodies where the mixture is placed on the market, if the mixture is classified as hazardous for human health or physical effects.

Distributor

A company is a distributor under CLP if they are based in the EEA and they source a chemical substance or a mixture within the EEA, store it and then place it on the market for someone else (may also be under their own brand without changing its chemical composition). Retailers and wholesalers are distributors. Their main obligations under CLP are:

Ensure the hazardous substances and mixtures they distribute are classified, labelled and packaged according to CLP before they are placed on the market.

Submit a poison centre notification (PCN) to the Appointed Bodies where the mixture is placed on the market, where they distribute mixtures classified for human health or physical effects in other Member States, or where they rebrand or relabel the mixtures, unless they can demonstrate a notification has already been submitted for that mixture in that Member State.