Chemicals
The CLP Revision: Digital Labelling and the DPP
Digital labelling under the CLP revision (EU) 2024/2865: which label elements stay physical, what the data carrier must offer and how it merges with the DPP QR
For decades the label on a chemical substance or mixture was entirely physical. The CLP revision in Regulation (EU) 2024/2865, published in November 2024, changed that: certain label elements may now be provided digitally through a data carrier. Arriving alongside the Digital Product Passport, it hands chemical exporters an opportunity and a design question: how many QR codes will the pack carry?
What the revision changed
The revision goes beyond the digital label. What matters to a chemical exporter:
- Readability: minimum font size and line spacing rules; clearer conditions for fold-out labels.
- Refill sales: label information must be available at the point of sale at refill stations.
- Distance sales: hazard information must be visible online before the purchase decision; advertisements carry it too.
- Digital label: certain elements may be provided through a data carrier.
The timetable is staged: different dates for substances and mixtures, plus transition periods for products already on the market. Confirm your product family's date in the regulation text. For the scope debate, see are chemical products in scope of ESPR.
What stays physical, what may go digital
The core principle is clear: every element needed for safety stays on the pack. The digital label complements the physical one; it does not replace it.
| Label element | On the physical label | On the digital label |
|---|---|---|
| Hazard pictograms | Mandatory | May be repeated |
| Signal word (Danger / Warning) | Mandatory | May be repeated |
| Hazard statements (H) and precautionary statements (P) | Mandatory | May be repeated |
| Supplier identity, product identifier, nominal quantity | Mandatory | May be repeated |
| Supplemental hazard information (EUH statements) | Mandatory | May be repeated |
| Supplementary information required by other EU legislation | Optional | May be digital only |
The last row is the digital label's current limit: what may be digital only is narrow, and the Commission may extend the list after an evaluation. For information from other legislation, such as the detergent ingredient list, see the Detergents Regulation and the digital label.
What the digital label must offer
The regulation also sets out how the digital label is provided, and the conditions mirror the DPP's public tier:
- The data carrier sits on the physical label, with a statement pointing to the digital label.
- Access is free of charge; no registration, app download or password may be required.
- The information is in the language of the member state of sale. See multilingual DPPs.
- It works with widely used devices and browsers and must be searchable.
- It must remain accessible for years after the product is placed on the market.
That list points the same way as the carrier and access rules of EN 18220; see what EN 18220 is.
One QR or two?
The biggest design risk is two competing codes on one pack: one for the CLP digital label, one for the passport. The consumer does not know which to scan, the inspector checks both, and the print area is halved.
The answer is a single QR built on GS1 Digital Link. The code carries the GTIN and, where needed, the batch number; a resolver service routes each scan by link type: CLP digital label for safety information, passport for product information, SDS for documents. The scanner sees one code, whatever sits behind it.
For code size and placement, see DPP QR code design.
Implementation steps for a chemical exporter
- Identify your product family's transition date; it differs for substances and mixtures.
- Split the label elements per the table above; redesign the physical label for the minimum font size.
- Generate the digital label from the structured substance data in DPP for chemicals, REACH and SCIP; no separate content pool.
- Set up the single-QR and resolver architecture; define the link types (safety information, passport, SDS).
- Manage a content version per market language and version every label change.
To plan alongside the pack's other labelling duties, see PPWR-compliant packaging labelling and the standards guide.
Frequently asked questions
Does the CLP digital label replace the physical label?
No. Pictograms, signal word, H and P statements, supplier identity, product identifier and nominal quantity stay on the pack; the digital label alone may carry only limited supplementary information.
Is a QR code mandatory for the CLP digital label?
The regulation imposes no technology; the carrier must be readable with widely used devices. In practice a GS1 Digital Link QR is the option most compatible with both CLP and the passport.
Is the CLP digital label the same as the Digital Product Passport?
No. The CLP digital label belongs to hazard communication; the passport is ESPR's product information instrument. They can share one data carrier and should draw on the same structured substance data.
