The CLP Regulation (EC) No 1272/2008 applies to a wide range of actors in the supply chain who manufacture, import, use, or distribute chemical substances and mixtures within the EU/EEA. Their responsibilities vary depending on their role:

Manufacturers, importers, and downstream users

• Must classify substances and mixtures before placing them on the market, based on available data and CLP criteria.
• Are responsible for labelling and packaging hazardous substances and mixtures in accordance with CLP requirements. 
• Must notify the classification and labelling of substances to ECHA’s C&L Inventory if not already submitted via a REACH registration. This applies to:
• Hazardous substances placed on the market (including imports);
• Substances in mixtures above classification thresholds;
• Substances subject to REACH registration or notification. 

Distributors

• Defined as entities that store and place on the market substances or mixtures without altering their chemical composition.
• Must ensure that products are correctly labelled and packaged according to CLP before sale.
• Are responsible for communicating safety information down the supply chain, including providing safety data sheets in the appropriate national language.

Suppliers

• The term “supplier” includes manufacturers, importers, downstream users, and distributors who place substances or mixtures on the market.
• All suppliers must ensure compliance with CLP labelling, packaging, and notification obligations.

Downstream users

• Are entities other than manufacturers or importers who use substances or mixtures in industrial or professional activities.
• Must classify substances or mixtures if they modify them or use them in a way that changes their classification.
• Re-importers (under REACH Article 2(7)(c)) are considered downstream users if the substance has already been registered upstream.