NonCLP

NonCLP is a term sometimes used in industry to describe a chemical substance or mixture that is not subject to the EU Classification, Labeling and Packaging (CLP) Regulation (EC) 1272/2008. It is not an official regulatory category. CLP primarily requires hazard classification and related labeling and packaging, so nonCLP generally implies that the item has no hazard classification under CLP or falls outside CLP’s scope.

Determining nonCLP status involves hazard assessment against the criteria in CLP and an assessment of regulatory scope. If, after assessment, no CLP hazard classes apply, or if the substance or mixture is otherwise outside CLP’s regulatory remit (for example due to being governed mainly by another regime or not placed on the EU market), it may be treated as nonCLP in business communications and documentation.

Implications for industry practice include the need to distinguish nonCLP from other regulatory obligations. A designation of nonCLP does not automatically relieve a supplier of duties under related frameworks. Substances placed on the EU market may still require compliance with REACH, such as registration or safety data sheets, and may be subject to sector-specific rules or labeling requirements under other regulations. Importers and distributors should verify applicable obligations in each regulatory domain rather than rely solely on a nonCLP label.

Caveats: because nonCLP is not formally defined in EU law, its meaning can be ambiguous and may vary over time or between jurisdictions. Documentation should reflect actual regulatory obligations and not rely solely on a nonCLP designation.