Supplemental Information on the Label of a Chemical Product
Supplementarl information on a CLP label refers to labeling elements specified in point (h) of Article 17 of the CLP Regulation and further defined in Article 25. This term covers those elements of the label that indicate additional hazards arising from the use of the product or provide extended information about the chemical product, which are not included in the basic scope of classification and labeling (i.e., H-phrases or P-phrases). In this article, we aim to answer the question of what supplementary information is and provide examples of such label elements.
What is Supplemental Information?
Letters (a) to (g) of Article 17 indicate the obligation to include:
- supplier information,
- product identifier,
- nominal quantity,
- pictograms,
- signal word,
- H-phrases,
- P-phrases.
Any information not included in the above list will be considered supplemental information. So, what might these include?
Paragraph 1 of Article 25 stipulates:
“Statements shall be included in the section for supplemental information on the label where a substance or mixture classified as hazardous has the physical properties or health properties referred to in sections 1.1 and 1.2 of Annex II.”
In the updated CLP Regulation (Regulation (EU) 2024/2865), paragraph 9 was added to Article 25, providing:
"Label elements resulting from requirements set out in other Union acts shall be placed in the section for supplemental information on the label."
Based on the above legal provisions, we can conclude that supplemental information includes primarily:
- EUH phrases,
- labeling elements required under legislation other than the CLP Regulation,
- other label elements, such as unknown toxicity phrases.
Further in this article we will focus on EUH phrases and other legal acts as the two most commonly required parts of the supplemental information.
EUH Phrases
EUH phrases are labeling elements specific to the CLP Regulation and labeling within the EU market. They do not derive directly from the GHS model rules, and their purpose is to supplement information on hazards or handling of the chemical product beyond what is possible with only H- and P-phrases.
Examples of EUH phrases include:
- EUH208: Contains <name of sensitizing substance>. May produce an allergic reaction.
- EUH401: To avoid risks to human health and the environment, comply with the instructions for use.
Although these are “supplemental” phrases, their use is mandatory and must not be omitted during hazard assessment of a substance or mixture, nor during label preparation.
Legislation Other Than the CLP Regulation
Within the European Union, the CLP Regulation is not the only legislation governing the placing of chemical products on the market. Some product groups require additional measures or the provision of more detailed information to the end user. These groups include detergents, aerosol products, and certain paints (the list is broader, of course).
Based on the relevant legislation, a chemical product label may require elements beyond the scope of the CLP Regulation. These elements are regarded as supplementary information under CLP.
This may include, for example:
- information on surfactants and fragrance compositions, in accordance with Regulation (EC) No 648/2004 on detergents,
- authorisation number for placing a biocidal product on the market,
- authorisation number under the REACH Regulation,
- VOC content for certain paints and varnishes.
It is important to remember that, in these cases, the CLP Regulation is not the overriding legislation, and the inclusion of these additional elements is just as important as including the appropriate H- or P-phrases.
How to Apply Supplemental Information in Practice?
✅ The selection of EUH phrases should comply with the requirements of the CLP Regulation – including this information is just as important as selecting the correct H- and P-phrases.
✅ Requirements from legislation other than CLP must be followed – based on the product type, one should verify which additional acts may apply.
✅ Supplemental information must be consistent with the content of the safety data sheet (Section 2.2 of the SDS).
✅ Translation matters – all phrases must be translated into the language of the country where the product is placed on the market.
Summary
Despite their name, supplemental information is not “optional” from the perspective of label preparation. It must be applied whenever required under the relevant legislation. Omitting supplemental information on the label constitutes non-compliance in the same way as failing to include H-phrases or P-phrases.
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