REACH and CLP in Practice: How to Correctly Classify and Label Industrial Cleaning Agents

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Industrial cleaning agents often contain highly effective substances that may pose a risk to health or the environment. Correct classification and labelling in accordance with REACH and CLP regulations are therefore essential not only for compliance with legal requirements but also for the protection of employees and end users. The process, however, is not straightforward – it requires knowledge of the chemical properties of raw materials, an understanding of harmonised criteria, and meticulous documentation. How can you proceed to avoid errors and ensure full compliance with the regulations?

REACH and CLP: The fundamental framework for industrial cleaning agents

Industrial cleaning agents are among the chemical mixtures subject to two key European regulations: REACH and CLP. REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) sets out obligations for the registration, evaluation, and potential restriction of substances, while CLP (Classification, Labelling and Packaging) focuses on the classification, labelling, and packaging of chemical mixtures. For manufacturers and distributors of cleaning agents, it is crucial to understand both regulations, as non-compliance can lead to legal penalties, product withdrawal from the market, or loss of customer trust.

REACH requires that all substances manufactured or imported into the EU in quantities exceeding one tonne per year be registered with the European Chemicals Agency (ECHA). For mixtures such as cleaning agents, individual components are registered. CLP then determines how the mixture should be classified and labelled based on its physico-chemical properties, toxicity, and ecotoxicity. For example, a cleaning agent containing strong acids or alkalis must be labelled with warning symbols and standard hazard statements (H-phrases) and safety instructions (P-phrases).

Classification of Cleaning Agents Under CLP: Step by Step

The classification of industrial cleaning agents under CLP begins with the identification of all mixture components and their properties. For each substance, it is necessary to determine whether it is already classified in the ECHA database or whether an independent assessment is required. Classification criteria include acute toxicity, corrosivity, irritancy, sensitisation, mutagenicity, carcinogenicity, reproductive toxicity, and ecotoxicity. For mixtures, the final classification is derived according to the rules for combining the hazardous properties of individual components.

The practical procedure involves several steps: First, safety data sheets (SDS) for all raw materials are collected. This is followed by an analysis of the concentrations of individual substances and their impact on the overall classification of the mixture. For example, a mixture containing more than 5% of a substance classified as corrosive to skin (Skin Corr. 1A) will automatically be classified as corrosive. If the mixture contains substances with different hazardous properties, rules for additive or synergistic effects are applied. The result is a final classification of the mixture, which determines what hazard pictograms, signal words ("Danger" or "Warning"), and hazard statements will be included on the label.

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Labeling and Packaging: How to Properly Present Hazard Information

Proper labeling of cleaning agents is crucial for ensuring user safety and compliance with legislative requirements. The label must include warning symbols (pictograms), a signal word, hazard statements (H-phrases), and safety instructions (P-phrases). Pictograms, such as the skull and crossbones for acute toxicity or the exclamation mark for corrosivity, must be clearly visible and not obscured by other information. The signal word "Danger" is used for more severe risks, while "Warning" is used for less severe ones.

In addition to mandatory elements, the label must also include the product name, supplier identification, quantity of the mixture in the packaging, and, where applicable, first aid instructions. For industrial cleaning agents, it is important that the information is understandable even for workers without specialized chemical training. For example, for a product with a high solvent content, the need for ventilation or the use of protective gloves should be emphasized. The packaging must also be resistant to chemicals and ensure safe storage and handling. In the case of large containers (e.g., drums), the label must be placed in an easily accessible location.

Safety Data Sheets (SDS): How to Compile and Update Them Correctly

The Safety Data Sheet (SDS) is a fundamental document for communicating the risks associated with industrial cleaning agents. It must be provided to all professional users and contain 16 mandatory sections covering the identification of the substance/mixture, hazard information, composition, first aid measures, fire-fighting instructions, measures in case of accidental release, handling and storage, exposure limits and protective measures, physical and chemical properties, stability and reactivity, toxicity, ecotoxicity, and other data.

SDS must be compiled in accordance with current standards and regularly updated. Changes in classification, new hazard data, or changes in the composition of a mixture require a revision of the document. For example, if a new substance with hazardous properties is added to the mixture, the SDS must be updated within 3 months. Distributors and manufacturers must ensure that all customers have access to the current version of the SDS, preferably through an online database or upon request. A properly compiled SDS not only meets legislative requirements but also protects the health of workers and minimizes risks when handling chemicals.

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Practical challenges in classifying multi-component mixtures

Industrial cleaning agents are often complex mixtures of dozens of substances, each of which may have different physico-chemical properties and toxicological profiles. The classification of such mixtures under the CLP Regulation requires a systematic approach that takes into account not only individual components but also their interactions. The basic rule is to assess each substance at a concentration above the threshold value specified in the CLP – for example, for substances with acute toxicity, this is usually 1% or 0.1%, depending on the hazard category. For mixtures containing substances with similar effects (e.g., corrosives), the principle of additivity applies, where the effects of individual components are summed.

A problem arises with mixtures where some components are not fully characterised or relevant toxicological data are missing. In such cases, a conservative approach must be used, and the mixture must be classified based on the available information, or experimental testing must be carried out according to standard test methods. It is also important to monitor updates in the ECHA databases, where new substance classifications are continuously added, which may affect the final classification of the entire mixture. In practice, it is advisable to use specialised chemical data management software, which automatically updates classifications based on the latest information.

Specific requirements for cleaning agents with bioactive components

Cleaning agents containing bioactive components, such as enzymes, preservatives, or antimicrobial substances, are subject to special classification and labelling rules. These substances may exhibit specific effects, such as skin sensitisation, irritancy, or toxicity to aquatic organisms, which must be reflected in the safety data sheet and on the label. Under the CLP Regulation, such mixtures must be classified not only according to their physico-chemical properties but also according to their biological effects, which often requires collaboration with toxicologists or specialised laboratories.

Special attention must be paid to cleaning agents intended for professional use in the food industry or healthcare, where safety and efficacy requirements are more stringent. For example, products with disinfectant properties must meet not only CLP requirements but also specific standards for biocidal products if they fall within the scope of the Biocidal Products Regulation. In such cases, it is necessary to ensure that the safety data sheet contains all relevant information on efficacy against microorganisms and clearly states any usage restrictions, such as the need for dilution or adherence to exposure time.

Updating Safety Data Sheets: When and How to Proceed

A Safety Data Sheet (SDS) is not a static document – it must reflect the current state of knowledge about a chemical substance or mixture. Under the REACH Regulation, it is the supplier’s obligation to update the SDS whenever new information on hazards emerges, the composition of the mixture changes, or legislative requirements are amended. Typical reasons for updates include new classifications of substances in the ECHA database, changes in exposure limits, or new findings on long-term health or environmental effects.

In practice, it is recommended to conduct a regular review of the SDS at least once a year, even if no obvious changes have occurred. It is also important to monitor feedback from customers, who may highlight practical issues when using the product, such as unexpected reactions or application difficulties. The updated SDS must be distributed to all recipients of the product within the last 12 months, in the language of the country where the product is placed on the market. To facilitate document management, it is advisable to use digital systems that enable automatic distribution of updates and version tracking.

Need Help with Classification?

Every chemical raw material supplied by GCG Group is provided with an up-to-date safety data sheet and technical documentation in compliance with REACH and CLP. Our experts will advise you on specific labeling requirements and the safe use of your products. Contact us – or browse our catalog of over 1,300 products right away.