CLP Compliance · Regulation (EC) No 1272/2008
Your CLP setup measured, from the classification file to the label on the drum.
10 themes, a 5-level scale. And the action that moves each level to the next.
The framework’s 10 themes, already written from L1 to L5. One company, one business unit, or 300 at once.
CLP Compliance · Regulation (EC) No 1272/2008
10 themes, 5-level scale.
Nordhavn Industries
53 / 100
They measure their maturity with Datamensio
An example
This could be your situation.
Take one company as an example: three sites, three spreadsheets, no shared answer.
Nobody can consolidate.
Nordhavn Industries, 2,400 people in Hamburg, Lyon and Porto. A client asks where the group stands. Each site answers in its own spreadsheet, with its own scales.
Three weeks, a single base.
One Regulation (EC) No 1272/2008 (CLP) assessment launched across all three sites at once, from the managers’ interview notes. The framework was already written, its 10 themes and levels L1 to L5 too.
Two costs avoided before being committed.
A score of 53 out of 100, with the gap concentrated on three themes. The AI companion spotted that two actions duplicated those of another audit. The committee report took one sentence to request.
What it saved them
- 3sites measured on the same base, instead of three questionnaires to reconcile
- 2duplicate actions caught before the spend
- 1committee report, with no manual rework
These figures are an example. They could be yours.
The standard imposes processes. Datamensio says where you stand.
01
The framework is already written
Themes, questions and levels L1 to L5, all written. You do not start from an empty spreadsheet.
02
The score lands the same day
Online, by self-assessment link or in interview. Theme by theme, comparable over time.
03
The gap becomes a costed plan
Every step up carries its action. The AI prioritises on expected effect, not on the order of the standard.
04
Progress can be demonstrated
Campaign after campaign, against your target and against your own past. That is what your board asks for.
The maturity scale
One level, the next, and the action that links the two.
It is this mechanism, one level, the level above, and the action linking the two, that turns an observation into a trajectory.
Does the labelling of containers used on site, including after decanting, reflect the classification applied?
- N1
No internal labelling rule. Some containers carry a handwritten note or no identification at all.
- N2
A rule exists and original containers are compliant, but decanting vessels are labelled inconsistently across workshops.
- N3
The rule is communicated and applied across all workshops. Labels carry pictograms and hazard statements. Gaps are occasional.
- N4
Labels are generated directly from the classification source, checked during planned rounds, and any gaps found are logged and corrected with a tracked deadline.
- N5
Any classification change triggers reprinting of the affected labels and withdrawal of obsolete ones, with periodic review of the setup’s effectiveness.
Action to move from level 2 to level 3
Provide each workshop with a set of pre-printed labels per product generated from the classification database, then add a labelling check to the weekly HSE round with a log of non-compliant containers.
« With Datamensio, we meet our objectives far more efficiently. The ERDF inspection services and our supervising ministry particularly appreciated an approach that gives them reliable data. »
Director, CCI 94CCI Île-de-France
« We believe this is the most suitable solution to scale our transformation project and measure impact according to our needs. »
Maja SucekChief Operating Officer, Interreg Danube
Rarely on its own
Frameworks combine. Put several together to cover your business, or have the AI write yours.
Take your first measurementon CLP.
What this framework covers
Regulation (EC) No 1272/2008, known as CLP, transposes the Globally Harmonised System of classification and labelling of chemicals into European law. It requires manufacturers, importers and downstream users to classify each substance and mixture according to physical, health and environmental hazard classes, to affix a compliant label (pictograms, signal words, hazard statements and precautionary statements), to comply with packaging and child-resistant closure rules, and to notify classifications to the ECHA inventory. The harmonised classifications in Annex VI apply as a matter of law.
On a mining site or a quarry, the subject is rarely owned by a single department. Explosives, flotation reagents, flocculants, laboratory acids, fuels and oils all coexist on the same site, each with a different status. Who decides on the classification of a concentrate or a valorised tailings product once it is placed on the market? Are the safety data sheets received from suppliers genuinely checked, or filed away unread? Do the labels on decanting containers in the workshop still reflect the original classification?
Two developments now shape the topic. The revision package adopted in 2024 introduces new hazard classes (endocrine disruptors, persistent, bioaccumulative and mobile substances), regulates online sales and refills, and clarifies label format rules. In addition, the Unique Formula Identifier, the UFI, must appear on the label of mixtures hazardous to health, linked to notification to poison centres. One confusion is worth clearing up: CLP addresses intrinsic hazard and its communication, while REACH addresses registration and conditions of use. The two feed into each other but do not replace one another.
A compliance audit settles the matter: the label is compliant or it is not, the notification was filed or it was not. The maturity assessment asks a different question: what level of control does the setup actually reach, and what specific action moves it to the next level. A correct classification produced by a lone expert, without procedure or traceability, is not equivalent to a classification produced by a documented, reviewed and verified process. The assessment distinguishes between these two situations, something an audit often fails to do.
Within Datamensio, the CLP framework is ready to use and adaptable. The AI adjusts the themes, rephrases the questions in the vocabulary of your sites, and refines the levels using the CMMI method, or builds a variant from your procedures, your SDS and your labelling instructions.
Reference standard: Regulation (EC) No 1272/2008 (CLP)
The themes assessed
Regulatory roles and scope
Identification of the company’s status (manufacturer, importer, downstream user, distributor) by flow, inventory of relevant substances and mixtures, coordination across sites and subsidiaries.
Classification of substances
Collection and assessment of available information, application of the harmonised classifications in Annex VI, justification of departures, treatment of substances from extraction and by-products.
Classification of mixtures
Application of calculation rules and thresholds, extrapolation principles, management of reformulations, review triggered by a change in composition or supplier.
Labelling and pictograms
Label content and format, signal words, hazard statements and precautionary statements, UFI, required languages, legibility and dimensions, secondary labelling of decanting containers.
Packaging and child-resistant closures
Container compliance, child-resistant fastenings, tactile warnings of danger, prohibition of attractive designs, conditions for on-site repackaging.
Notifications and declarations
Notification to the ECHA classification and labelling inventory, declarations to bodies designated for emergency health response, harmonised classification proposals, deadline tracking.
Safety data sheets and communication
Consistency between classification, label and SDS, checking of incoming SDS, distribution to operators and subcontractors, availability in the event of a classification change.
Skills and training
Persons designated to classify, operator training in reading labels and pictograms, induction for temporary staff and contractors, authorisations linked to sensitive products.
Monitoring and change management
Tracking of adaptations to technical progress, integration of new hazard classes, anticipation of transitional periods, impact on existing labels and stocks.
Internal control and traceability
Planned checks on the ground, recording of classification decisions and their supporting evidence, data retention, handling of gaps and follow-up actions.
A short version of the framework is available for the online self-assessment.
Frequently asked questions
Does the CLP assessment deliver a compliance certificate?
No. CLP is not a certifiable framework: it applies directly and compliance is checked by national authorities. The assessment measures the maturity of your setup, documents gaps and prepares for inspection. It does not replace any official verification.
How does this differ from a regulatory compliance audit?
An audit concludes with a gap or a pass on each requirement. The assessment places your practices on a maturity scale and identifies the action that moves you up a level. The two complement each other: the assessment prioritises effort, the audit validates the outcome.
How long does the evaluation take?
The short version can be completed in a single working session. In collaborative mode, involving product regulatory affairs, HSE and site operators, the campaign runs over one to two weeks, most of the time spent gathering classification evidence and field records.
Can the framework be adapted to our products and sites?
Yes. The themes, questions and levels can be modified, and the AI can build a variant from your procedures, your SDS and your labelling instructions. You retain ownership of the resulting framework.
How do CLP and REACH fit together in a single programme?
CLP addresses hazard and its communication, REACH addresses registration and conditions of use. Both frameworks share source data. A cross-cutting roadmap consolidates the two assessments to avoid duplicating actions on the same substances.
Are the new hazard classes taken into account?
Yes. The framework includes a dedicated theme on monitoring and change, covering adaptations to technical progress, the new classes introduced by the regulation’s revision, and the impact on existing labels and stocks.
Can several sites be compared with each other?
Yes. Each site is assessed against the same framework, making scores comparable by theme. The benchmark positions each business unit against the others and against its own previous assessments.
Where is the data hosted?
In France, with OVH, with backup at Scaleway. No transfer outside the European Union. The AI models used can be selected, including from European providers.