The CLP regulation serves as a fundamental framework for assessing and communicating the hazards of substances and mixtures, as minor as they might be. It is NOT a risk assessment framework.

A purely “biological” and “natural” origin of components does not make a plant biostimulant “non hazardous” within the frame of the CLP.

Even plant biostimulants, regardless of their composition and mode of action, are subject to the CLP.

The right to place a product on the market without prior authorisation does not remove the obligation for classification and labelling according to the CLP.

Packaging: General CLP packaging and labelling standards are relevant in all EU Member States

The responsibility for the classification and labelling of a product, like a biostimulant, is with manufacturers, importers and downstream users.

Just to be clear: "Downstream users" are not consumers, nor distributors, but most biostimulant manufacturers (formulating products from raw/starting materials sourced from suppliers) would qualify as “downstream users”.

It is important because the CLP will help to define a hazard profile and this has implications on the product label and Material Safety Data Sheet (consequences on, for instance, transport regulations). As a product is also considered a "mixture", the CLP also applies to biostimulants and fertilisers.

Mind you: it could well be that your product will not be "classified according to the CLP", but that finding is not based on guess-work or intuition, but on an assessment based on the composition and hazard properties of the ingredients of the mixture!