REACH and CLP in Practice: How to Correctly Classify and Label Industrial Adhesives and Sealants

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Manufacturers and processors of industrial adhesives and sealants face daily challenges with REACH and CLP/GHS regulations. These regulations not only determine what information must be included on labels and in Safety Data Sheets (SDS), but also how to correctly classify the hazardous properties of individual components. An error in labeling or missing information can lead to penalties, as well as endangering the health of workers or damaging the environment. In this article, we will look at the key steps to follow when working with these chemical mixtures and how to avoid common legislative pitfalls.

REACH and CLP: The Basic Framework for Adhesives and Sealants

The REACH Regulation (Registration, Evaluation, Authorisation and Restriction of Chemicals) and the CLP Regulation (Classification, Labelling and Packaging) form the cornerstone of safe handling of chemical substances in the European Union, including industrial adhesives and sealants. REACH focuses on the registration and evaluation of substances, while CLP sets out the rules for their classification, labelling and packaging. For manufacturers and distributors of adhesives and sealants, it is crucial to understand both regulations, as compliance with them is mandatory for all substances and mixtures placed on the EU market.

REACH requires that all substances manufactured or imported in quantities exceeding one tonne per year be registered with the European Chemicals Agency (ECHA). This also includes individual components of adhesives and sealants if they meet this volume threshold. CLP then ensures a harmonised system for classifying hazardous properties, such as toxicity, flammability or corrosivity, and defines mandatory labelling on packaging and in Safety Data Sheets (SDS). For adhesives and sealants, which often contain reactive components or solvents, correct classification under CLP is essential for protecting users and the environment.

Classification of Adhesives and Sealants under CLP: Step by Step

The classification of adhesives and sealants under the CLP Regulation begins with identifying the hazardous properties of the individual components of the mixture. The manufacturer must first determine whether any of the components fall into any of the hazard categories defined in CLP, such as corrosive, sensitising or flammable liquid. This information can be obtained from suppliers' Safety Data Sheets or the ECHA database. If the mixture consists of multiple substances, it is necessary to assess their interactions and possible synergistic effects, which may influence the overall classification.

Next, the rules for classification of mixtures according to CLP are applied. For adhesives and sealants, the most relevant categories include acute toxicity, skin and eye irritation, respiratory or skin sensitization, and hazards to the aquatic environment. For example, epoxy adhesives often contain components that can cause skin sensitization and must therefore be classified as "May cause an allergic skin reaction." For each identified hazardous property, the appropriate pictograms, signal words ("Danger" or "Warning"), standard hazard statements (H-phrases), and safe handling instructions (P-phrases) are then determined.

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Labelling and Packaging: How to Correctly Present Information on the Packaging

The labelling of adhesives and sealants must comply with CLP requirements and must provide users with clear and understandable information about the hazards associated with the product. All mandatory elements must be stated on the packaging: hazard pictograms, signal word, H-statements and P-statements, supplier identification, and the name of the mixture. The pictograms must be legible and placed in a visible location, with their size not less than 1 cm² for packages up to 3 litres and 2 cm² for larger packages.

For adhesives and sealants containing volatile organic compounds (VOCs) or reactive components, it is also important to provide specific storage and handling instructions. For example, for anaerobic adhesives, which cure in the absence of air, the packaging must clearly state that the product must not be stored in open containers. Furthermore, it is necessary to provide the supplier's contact details for emergencies, including the telephone number of the toxicological information centre. All this information must be provided in the official language of the country where the product is placed on the market, which in the Czech Republic is Czech.

Safety Data Sheets (SDS): A Key Document for Safe Use

The Safety Data Sheet (SDS) is a fundamental document that must accompany every industrial adhesive or sealant placed on the market. The SDS provides detailed information on the chemical composition, hazardous properties, safe handling measures, first aid, and product disposal. Under the REACH regulation, the SDS must be updated whenever new hazard information becomes available or the product composition changes. For adhesives and sealants, the SDS is essential not only for compliance with legislation but also for ensuring worker safety and environmental protection.

SDS must contain 16 mandatory sections that cover everything from the identification of the substance/mixture and the supplier, through hazard classification, composition, first aid measures, to disposal and transport instructions. For adhesives and sealants, sections concerning stability and reactivity are particularly important, as these products often contain reactive components that can cause hazardous reactions if stored or handled improperly. SDS must be provided in printed or electronic form and must be easily accessible to all users, including workers in production facilities and laboratories.

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Risk Assessment and Exposure Scenarios: How to Proceed with Adhesives and Sealants

Every manufacturer or importer of adhesives and sealants must conduct a risk assessment in accordance with REACH requirements. This process involves identifying the hazardous properties of raw materials, determining exposure scenarios, and evaluating risks for different user groups – from industrial workers to professional tradespeople. For adhesives and sealants, it is crucial to consider not only acute toxicity but also long-term effects, such as skin sensitisation or respiratory tract irritation. Exposure scenarios should cover all stages of the product life cycle, including mixing, application, curing, and subsequent processing of bonded materials.

For a proper assessment, it is necessary to gather data on the physico-chemical properties, toxicological, and ecotoxicological profiles of individual components. If relevant studies are not available, expert estimates or analogues of similar substances can be used. The results of the risk assessment are then reflected in safety data sheets (SDS) and exposure scenarios, which must be available to all users in the supply chain. For professional applications, worker training and adherence to specific protective measures, such as the use of personal protective equipment or ensuring adequate ventilation, are often required.

Communication in the Supply Chain: How to Share Information on Hazardous Substances

Effective communication about hazardous substances in the supply chain is essential to ensure safety and compliance with legislation. Under REACH, every participant in the chain must pass on information about substances and mixtures both downstream and upstream. This means that manufacturers of adhesives and sealants must provide updated safety data sheets to their distributors and customers, while the latter are obliged to report on the product's use to enable the assessment of risk scenarios. Distributors then play a key role in conveying this information to end users, including recommendations for safe handling.

In practice, this means that any change in the product composition, its classification, or safety measures must be promptly communicated to all relevant parties. For example, if one raw material is replaced with another with a different hazard profile, the safety data sheet and the corresponding labeling on the packaging must be updated. Electronic SDS management systems are often used to facilitate communication, enabling rapid dissemination of updates. It is also important to train employees who work with this information so they can correctly interpret and convey key data.

Practical Tips for Compliance: How to Minimize Administrative Burden

Compliance with REACH and CLP regulations can be administratively demanding for manufacturers and distributors of adhesives and sealants, but there are ways to streamline the process. The first step is to centralize documentation management—creating a unified system for storing safety data sheets, exposure scenarios, and certificates. This facilitates updates and ensures that all relevant information is easily accessible for internal and external audits. Additionally, it is advisable to use specialized chemical management software that automatically generates and updates SDS in line with current legislative requirements.

Another tip is to provide regular training for employees involved in classification, labeling, or supply chain communication. Knowledge of current regulations and procedures helps prevent errors and unnecessary penalties. For smaller companies, collaborating with external consultants or associations that offer support in chemical legislation can be advantageous. Furthermore, it is important to monitor regulatory updates and engage in professional discussions, for example through industry associations, to respond promptly to new requirements.

Do you have questions about legislative compliance?

GCG Group provides complete safety documentation, including SDS and technical data sheets, for every raw material supplied for the production of adhesives and sealants. Our experts will advise you on classification, labeling, and other legislative requirements to ensure your products meet all regulations. Contact us – or browse our catalog of over 1,300 products right away.