Obligations

Key information on the CLP regulation

Whether you are user, manufacturer or importer of chemical substances, you are concerned by the new CLP regulation (Classification, Labeling and Packaging) based on the UN Globally Harmonised System (UN GHS).

The CLP regulation affects most chemicals: substances and mixtures, and issues new rules on the classification, labeling and packaging of these products.

In practical terms, the CLP regulation redefines the classification criteria of hazards, introduces new labels and updates the Safety Data Sheets (SDSs) including new pictograms, hazard and precautionary statements, etc.

From 1 December 2010 the following rules apply:

Substances must be classified in accordance with both DSD and CLP;

Substances must be labelled and packaged in accordance with CLP only, but substances already classified, labelled and packaged according to DSD and placed on the market (i.e. "on the shelf") before 1 December 2010 will only have to be re-labelled and re-packaged by 1 December 2012;

Until 1 June 2015, mixtures must continue to be classified, labelled and packaged in accordance with the Dangerous Preparations Directive, DPD. However, a mixture may also be classified, labelled and packaged according to CLP before this date. When this is done, the labelling and packaging provisions of DPD shall no longer apply to the mixture. This means that labelling and packaging must respect the provisions of CLP;

Until 1 June 2015, the classification of a substance according to DSD must be provided in the Safety Data Sheet, in addition to the CLP classification. This will be both apply to Safety Data Sheets for substances on their own and to Safety Data Sheets for mixtures containing these substances;

Until 1 June 2015, the classification of a mixture according to DPD must be provided in the Safety Data Sheet;

Until 1 June 2015, if a mixture is classified, labelled and packaged according to CLP, the CLP classification must appear on the Safety Data Sheet, alongside the classification based on the DPD. However, a supplier may choose to indentify the CLP classification of a mixture in advance of applying CLP to it in full. Where this happens, the supplier may include this information on the accompanying Safety Data Sheet, under the 'other information' heading.

Source: ECHA newsletter 2010_08_16

CLP compliance: the sooner the better

CLP-compliance is a three-step process: classification, notification and update of labels and SDSs.

STEP 1: Classification

What: hazardous substances and mixtures must be classified
Who: manufacturers, importers and downstream users, including distributors
How: classifying a substance or a mixture is a complex process that must go through the judgment of an expert

STEP 2: Notification

What: all hazardous substances as well as REACH-affected substances must be notified to ECHA, while mixtures are free from notification.
Who: manufacturers and importers only have to submit a notification to ECHA
When: already marketed substances: 3 January 2011
Substances marketed after 1 December 2010 have a month' delay

STEP 3 : Labels and Safety Data Sheet (SDS)

Click here to know more about labels and SDS under CLP

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