CLP Labeling of Chemical Products in Ukraine: Deadlines and Requirements

Your product is already on the market, but does its label meet the new requirements? Since November 2024, the Technical Regulation on the classification, labeling, and packaging of chemical products—the Ukrainian version of the European CLP—has been in effect in Ukraine. This is not a recommendation, but a mandatory regulation. Non-compliance means fines, removal from shelves, and the closure of export markets.

In this article, we analyze exactly what has changed, which pictograms and phrases must be on the label, when the key deadlines occur, and how to prepare without panic.

What are CLP and GHS: Briefly on the Main Points

GHS (Globally Harmonized System) is a globally harmonized system for the classification and labeling of chemicals developed by the UN. Its goal is uniform rules for the entire world: the same pictograms, signal words, and hazard phrases from Tokyo to Toronto.

CLP (Classification, Labelling and Packaging) is the European implementation of GHS, operating in the EU since 2009 in the form of Regulation (EC) No 1272/2008. Ukraine took CLP as the basis for its Technical Regulation.

UA-CLP is the Technical Regulation "On the classification, labeling and packaging of chemical products," approved by Resolution No. 539 of the КМУ (Cabinet of Ministers of Ukraine) dated May 10, 2024. It entered into force on November 15, 2024.

If your company already works with the European CLP, most requirements will be familiar. If not, it is time to understand them, as the transition periods are limited.

SVK relabeled all its products in accordance with UA-CLP even before the regulation entered into force. In our experience, the complete transition of an assortment of 200+ items took 5 months—including the translation of H/P-phrases, recalculation of classifications for mixtures, and updating label designs.

> Read more about the parallel REACH regulation in the article "UA-REACH: What Manufacturers Need to Know".

9 GHS Hazard Pictograms

Each pictogram is a red diamond with a white background and a black symbol. Here is the complete list:

Important: A single label can have multiple pictograms, but there are precedence rules. For example, if GHS06 (skull) is required, GHS07 (exclamation mark) is not used for the same hazard.

Signal Words: "Danger" vs. "Warning"

UA-CLP provides only two signal words:

There can be only one signal word on the label. If a substance falls under both, "Danger" is indicated as the more severe.

H-phrases and P-phrases: The Language of Hazard

H-phrases (Hazard Statements)

Each hazard category corresponds to a standardized phrase with a unique code:

P-phrases (Precautionary Statements)

The language of the phrases on the label is Ukrainian. However, the H/P codes remain international.

UA-CLP Deadlines: Key Dates

The UA-CLP Technical Regulation entered into force on November 15, 2024, but implementation is happening in stages. The government extended the transition periods (Resolution of the КМУ (Cabinet of Ministers of Ukraine) dated October 22, 2025), considering martial law and the limited resources of businesses.

Current Schedule (Including Extensions)

What This Means for Business

• Right now: New products must be released with a CLP label.
• By November 2025: Old products on the market must be relabeled or withdrawn.
• By November 2027: Full classification of all individual substances.
• By May 2028: Full classification and labeling of all mixtures.

> Do not wait until the last day. Preparing a classification dossier for a single substance takes 2 to 6 weeks. We recommend reviewing the ECHA Guidance on classification and labelling as an authoritative source for understanding GHS/CLP principles.

Safety Data Sheet (SDS): 16 Mandatory Sections

The Safety Data Sheet (SDS) is an integral companion to CLP labeling. For every hazardous substance or mixture, the manufacturer or importer is required to compile an SDS in Ukrainian.

The SDS structure under UA-REACH includes 16 sections:

> The connection between CLP and SDS: Section 2 of the safety data sheet directly references the CLP classification. Incorrect classification = incorrect SDS = violation.

Checklist: What Must Be on a CLP Label

Use this list to verify each product:

• [ ] Product name (chemical name of the substance or trade name of the mixture)
• [ ] Substance identifier (CAS number, EC number, IUPAC name)
• [ ] Hazard pictogram(s) — red diamond, at least 1 cm × 1 cm (area not less than 1/15 of the label)
• [ ] Signal word — "Danger" or "Warning"
• [ ] H-phrases — all relevant ones, in Ukrainian
• [ ] P-phrases — no more than 6 (select the most important), in Ukrainian
• [ ] Nominal quantity — volume or mass in consumer packaging
• [ ] Supplier details — name, address, telephone of the manufacturer/importer/distributor
• [ ] Supplemental information — EUH-phrases (if necessary)

Label size depends on the container volume:

FAQ

Is CLP labeling required for household chemicals?

Yes. Any chemical mixture that has at least one classified hazard (skin irritation, flammability, etc.) must have a CLP label—regardless of the sales channel. This applies to laundry detergents, cleaning agents, disinfectants, adhesives, and paints. Read more about the requirements for household chemicals in the article "Requirements for Household Chemicals for Export to the EU".

What is the difference between UA-CLP and European CLP?

Structurally, UA-CLP is maximally harmonized with Regulation (EC) 1272/2008. The main differences are the supervisory authority (in Ukraine, the Ministry of Economy), the language of labeling (Ukrainian), and the dates of the transition periods. The classification, pictograms, and H/P-phrases are identical.

What are the penalties for violating labeling requirements?

Products without proper labeling are subject to withdrawal from circulation. Manufacturers and importers bear administrative responsibility. Furthermore, without correct CLP, export to EU countries is impossible—the goods will not pass customs control.

Is a new classification needed if the product already has European CLP?

If a substance or mixture is already classified under EU Regulation 1272/2008, the classification results can be used. However, the label must be in Ukrainian, with the details of the Ukrainian supplier, and comply with the UA-CLP format.

SVK Will Help with Labeling

Preparing CLP labeling is not just about "sticking on a diamond." It is necessary to classify each component, determine the pictograms and phrases, compile a safety data sheet, and design the label in the correct format.

SVK offers:

• Classification of substances and mixtures under UA-CLP—determining hazard classes based on toxicological data
• Development of Safety Data Sheets (SDS)—a complete 16-section document in Ukrainian
• CLP label design—with the correct pictograms, phrases, and dimensions
• Consultations on transition periods—an individual compliance plan for your assortment
• Preparation for notification to poison centers—formation of a PCN dossier

📩 Get a consultation on CLP labeling →

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Read Also

• UA-REACH: What Manufacturers Need to Know
• Requirements for Household Chemicals for Export to the EU
• PFAS Ban in the EU: What Will Change for the Chemical Industry
• Glossary of Industrial Chemistry