How an Aerosol Is Labelled Under the CLP Regulation
The CLP Regulation (EC 1272/2008) is the European rule that requires hazardous substances and mixtures to be classified, labelled and packaged. On an aerosol, the label carries the flame pictogram if it is flammable, the signal word Danger or Warning, the H222 or H223 statement depending on its category, always H229, and its precautionary statements.
What CLP Requires of Your Aerosol Before You Design the Label
Regulation (EC) 1272/2008 is known as CLP: classification, labelling and packaging. It brings the United Nations Globally Harmonised System (GHS) into the EU, the same scheme of hazard classes, pictograms and statements used in other countries, so an aerosol is classified on the same criteria in Lleida as in Hamburg.
CLP groups hazards into three families: physical (explosives, flammables, gases under pressure, aerosols), health (toxicity, irritation, sensitisation) and environmental. An aerosol always belongs to the physical hazard class of aerosols and, in addition, to whatever classes its formula calls for. The REACH helpdesk fact sheet published by the Spanish Ministry for the Ecological Transition sums up its scope:
The CLP Regulation requires companies to classify, label and package their chemical products, and to notify certain mixtures to poison centres before placing them on the market, in accordance with legally binding rules.
Before ordering the artwork, check two things in section 2 of your mixture's safety data sheet: which hazard classes it falls into besides aerosols, and whether the mixture must be notified to poison centres before you sell it.
Which Pictograms Your Aerosol Carries and How to Check Them
A hazard pictogram is a red-bordered diamond with a black symbol on a white background that identifies the type of hazard at a glance. CLP defines nine:
| Code | Symbol | Hazard it signals |
|---|---|---|
| GHS01 | Exploding bomb | Explosives |
| GHS02 | Flame | Flammables, aerosols included |
| GHS03 | Flame over circle | Oxidisers |
| GHS04 | Gas cylinder | Gases under pressure |
| GHS05 | Corrosion | Skin corrosion and serious eye damage |
| GHS06 | Skull and crossbones | Severe acute toxicity |
| GHS07 | Exclamation mark | Irritation, mild acute toxicity |
| GHS08 | Health hazard | Serious or chronic effects |
| GHS09 | Environment | Hazard to the aquatic environment |
A flammable aerosol carries GHS02. If the formula is also irritant or hazardous to the aquatic environment, it adds the pictograms that apply. To review your label, put section 2 of the safety data sheet beside it and compare its pictograms one by one with those on the artwork: none should be missing and none should be extra.
What Do H222 and H229 Mean on an Aerosol?
H222 means "extremely flammable aerosol" and H229 means "pressurised container: may burst if heated". They are hazard statements and depend on the aerosol's category, which CLP assigns from the content of flammable components, the heat of combustion and, where needed, ignition tests:
| Category | Pictogram | Signal word | H statements | P statements |
|---|---|---|---|---|
| 1, extremely flammable | Flame (GHS02) | Danger | H222 and H229 | P210, P211, P251, P410+P412 |
| 2, flammable | Flame (GHS02) | Warning | H223 and H229 | P210, P211, P251, P410+P412 |
| 3, non-flammable | None | Warning | H229 | P210, P251, P410+P412 |
An aerosol with 85 % or more flammable components and a heat of combustion of at least 30 kJ/g is category 1 without further testing; with 1 % or less and under 20 kJ/g it is not considered flammable. Between those extremes, the ignition distance, enclosed space or foam ignition tests decide.
The precautionary statements turn the hazard into behaviour: keep away from heat and ignition sources (P210), do not spray on a flame (P211), do not pierce or burn the container, even after use (P251), and protect it from sunlight and temperatures above 50 ºC (P410+P412).
What Goes on an Aerosol Label
The label combines what CLP requires with what the EU Aerosol Dispensers Directive 75/324/EEC adds, transposed in Spain by Royal Decree 1381/2009. The Directive requires even a non-flammable aerosol to carry the signal word and statements of its CLP category, and adds statement P102 (keep out of reach of children) when the aerosol is a consumer product.
- Supplier
- name, address and phone number
- Product identifier
- name and key components
- Hazard
- pictogram, signal word, H statements
- Precaution
- P statements for its category
- Container marking
- inverted epsilon
- Batch
- an identifying code
- Contents
- stated by volume
- Language
- that of each country of sale; in Spain, at least Spanish
An aerosol that contains flammable components but is not classified as flammable must also state on the label the percentage by mass of flammable components it contains.
💡 Technical tip: check the category against the actual heat of combustion of the mixture before fixing the pictogram. A change of solvent or propellant supplier can move the product into another category without changing how it looks or how it is used.
What Changes on the Label from 2028
The CLP revision adopted in 2024 (Regulation EU 2024/2865) adds formatting rules for the label: minimum font sizes according to container capacity, line spacing, colour and typeface. According to the same Ministry fact sheet, the postponement regulation 2025/2439 pushed the mandatory date back to 1 January 2028, although the rules can already be applied voluntarily.
For a 400 ml aerosol whose label is already tight, the change may mean redesigning the artwork or moving to a fold-out label. It is worth reviewing at the next redesign, not in the last quarter of 2027.
If you are launching or relabelling an aerosol under your own brand, Ilerspray manufactures it with its CLP labelling, lithographed or self-adhesive, as part of its aerosol contract manufacturing service.
