Adhesives, glue, sealants and fillers

• Regulation (EC) No 1272/2008 — CLP
• Regulation (EC) No 1907/2006 — REACH, including the diisocyanate restriction
• Regulation (EU) 2023/988 — GPSR
• Regulation (EU) 2024/3110 for construction products where covered

Who has to appoint one

Manufacturers and sellers outside the Union placing adhesives and sealants on the EU market. Products containing diisocyanates are subject to a specific REACH restriction requiring training of users before industrial or professional use.

Thresholds and exemptions

CLP applies to any classified mixture. The diisocyanate restriction applies above 0.1% by weight, with mandatory training and a specific label statement.

What must appear on the label

CLP pictograms and statements, product identifier, nominal quantity, the supplier's EU details, the UFI code, and for diisocyanate products the statement that use is restricted to trained users from 24 August 2023. Cyanoacrylate adhesives carry specific warnings on skin and eye bonding.

Marketplace fields

Marketplaces check CLP labelling in listing images, and adhesives are subject to transport restrictions that affect which fulfilment channels can be used.

Documentation you must hold

CLP classification file, safety data sheet per language, poison centre notification with UFI, REACH compliance evidence, and where the product is a construction product with a harmonised standard, the declaration of performance.

Standards and testing

Classification testing or calculation, and performance testing against the applicable standard where a construction performance is declared.

Language requirements

Label, hazard statements and safety data sheet in the language of each member state of sale.

When it applies

Notification and labelling before the first sale in each member state.

How long records are kept

Ten years.

What happens if you do not comply

Withdrawal and fines. The diisocyanate restriction has been actively enforced since 2023 and non-compliant labels are a frequent finding.

Who enforces it

National chemicals authorities, poison centres and market surveillance.

Where the boundary lies

A structural adhesive covered by a harmonised construction standard needs a declaration of performance in addition to the chemical duties, which is a different document from the safety data sheet and is often missing.

Questions we are asked

What changed for diisocyanates?

Since August 2023 products above 0.1% may only be used after mandatory training, and the label must state this. Sellers must be able to show the training route exists for their customers.

Is super glue classified?

Cyanoacrylates carry specific labelling requirements including skin and eyelid bonding warnings, and most are classified under CLP.