Hazardous Substances in the B2B Shop: Labelling and SDS

Three layers interlock. At European level the CLP Regulation governs classification, labelling and packaging, while the REACH Regulation governs the safety data sheet. Nationally, German rules on handling hazardous substances at work and on the supply of chemicals are added. For the shop this means: classification decides pictograms and signal word, the safety data sheet decides the document duty, the supply rules decide the ordering route. Under law already in force, advertising for a mixture classified as hazardous that lets a private end user conclude a purchase without prior sight of the label must state the hazards. That is Article 48(2) (CLP Regulation). The provision therefore bites where a private end user can conclude without having seen the label first - in a pure B2B channel usually not, in mixed shops and on open marketplaces it does. Setting the frame up once in an ordered way, rather than retrofitting rule by rule, saves the second round; how we approach this for merchants with a hazardous goods range is described on the page about B2B e-commerce for chemicals and plastics.

The second layer is time. Chemicals law changes continuously, and each change brings its own deadlines. The CLP reform under Regulation (EU) 2024/2865 fixed minimum label dimensions, a minimum font size and a minimum line spacing; delegated Regulation (EU) 2023/707 introduced new hazard classes for endocrine disruptors and for persistent, mobile and bioaccumulative substances. A catalogue of a few thousand items does not pass through those deadlines in one go but item by item. That is exactly why every classification in the shop needs a date and a processing status. Without that field neither can maintenance be planned, nor can it later be shown which version applied when.

The CLP reform wrote down formalities that used to be guidance. For small packages up to 0.5 litres (Regulation EU 2024/2865) the new version prescribes a minimum x-height of 1.2 millimetres (Regulation EU 2024/2865), and for all labels a line spacing of at least 120 percent (Regulation EU 2024/2865) of the font size. The version in force today sets, for packaging up to 3 litres (CLP Regulation), a label format of at least 52 by 74 millimetres and pictograms of at least 16 by 16 millimetres, in no case smaller than 10 by 10 millimetres. At the upper end, packaging above 500 litres (Regulation EU 2024/2865) already carries today a label of at least 148 by 210 millimetres with pictograms of at least 46 by 46 millimetres; new in that row is only the minimum x-height of 2.0 millimetres.

Further size brackets sit between those anchors; the table deliberately shows only the values that can be quoted verbatim. Two points matter for the shop. First, label dimensions belong on the item as a field, because they determine how much text fits on the pack - and therefore, indirectly, which precautionary statements get printed. Second, the CLP Regulation normally limits the label to no more than six (CLP Regulation) precautionary statements. For very small packages up to 125 millilitres (CLP Regulation) certain relaxations apply under defined conditions. Showing more statements in the offer than on the pack is not an infringement, but it is a discrepancy that has to be explained when a complaint arrives.

German chemicals supply law defines to whom certain substances and mixtures may be supplied. The central provision for a shop is Section 10(1) (ChemVerbotsV): for the substances it covers, the dispatch route is closed outside the group of recipients defined in Section 5(2) - resellers, professional users and public research, testing and teaching institutions belong to that group. The self-service ban sits in a different provision: Section 8(4) ChemVerbotsV prohibits supply through vending machines and other forms of self-service in retail. That is not a labelling matter but an ordering matter. A shop may carry those items, but the route to the order must be a different one - enquiry instead of cart, collection with identity check instead of parcel dispatch, or release only for a vetted group of recipients. Pulling the block only in the dispatch process means the infringement was arguably already built into the checkout.

Further conditions apply on the supplier's side. Whoever supplies substances subject to a permit must, among other things, be at least 18 years (ChemVerbotsV) old, hold the required expertise and be reliable. That expertise is not permanent: where it was acquired more than six years ago, training has to be shown - a one-day course from the last six years (ChemVerbotsV) or a half-day course from the last three years (ChemVerbotsV). For the shop this means an expiry date on a person's role, not on an item. And it means the check runs both ways: the buyer may receive, and the supplier may supply. Anyone who already sets up customer accounts with vetted evidence has done half the work - see onboarding and registration of business customers.

Since 1 May 2025 (Regulation EU 2023/707) substances have to be classified under the new hazard classes, and since 1 May 2026 (Regulation EU 2023/707) the same applies to mixtures. For mixtures placed on the market before that date a transition period runs until 1 May 2028 (Regulation EU 2023/707). This is why a catalogue carries two classification states side by side for years. Without a status field on the item, remaining stock cannot be told apart from new production - and precisely that distinction decides which label and which safety data sheet are correct.

When a classification changes, a deadline starts for the label. Where the classification becomes stricter, the labelling has to be adjusted within six months (Regulation EU 2024/2865) of the review result; for all other changes a deadline of 18 months (Regulation EU 2024/2865) applies. In parallel, classification and labelling records must be kept for at least ten years (CLP Regulation) after the last supply. Three deadlines on one item, moving independently of each other: that is not a job for a spreadsheet but for a dated field and a report listing the items that fall due. The logic is close to that of traceability, see batches, serial numbers and traceability.

All of the above converges on one structure. The item carries the classification with its status and date. The labelling elements hang off it as code lists, with wording from language-dependent lookup tables. The safety data sheets form a list of objects with language, version, format state and validity date. The supply rules form their own block with dispatch ban, eligible recipients, required evidence and logging duty. Fields for UFI and dangerous goods come on top. Such a structure costs more time to set up than a single attachment field - and gives that time back at every deadline change.

The second building block is provenance. Each of these fields needs a leading system, and as a rule that is not the shop. Classification and safety data sheet come from wherever the formulation is maintained; dangerous goods data hang off the logistics master record; the evidence on the customer account is created by sales. The shop receives and displays, but it is also the place where a gap becomes visible immediately. That is why a blocking mechanism beats a silent display: if a mandatory field is missing, the item is not shown without the information but blocked for the affected route. The same thinking carries over to other data duties, for instance the digital product passport - and in both cases it starts with data quality in the PIM.

A hazardous goods range cannot be converted in one pass. What works is a sequence that shows effect early and makes the rest plannable. It starts with the items that generate the most queries and complaints today and works towards the rare cases. What matters is that every stage leaves a visible state - a list that gets shorter, rather than a project that runs.

Whether the effort pays off is partly decided by the state of the industry. Germany's chemical and pharmaceutical sector last worked at a plant utilisation of around 70 percent (VCI), a historic low, spread across the roughly 2,300 companies (VCI) the industry association counts as members. In such an environment, cutting administrative work is not a side issue. The European Commission puts the relief from simplified font size requirements alone at at least 333 million euros (European Commission) and the narrowing of advertising duties at at least 30 million euros (European Commission) per year - both so far proposals, not law in force. For planning that means: build on the deadlines in force, watch the proposals. Where we support that work is set out under services; for a range containing hazardous goods the direct route is the page on chemicals and plastics. Adjacent ranges follow the same logic, for instance equipment hire in a B2B shop.