Prerequisites
Do you know what CLP regulation is (Classification, Labelling and Packaging)? Do you know major changes regarding the former classification system DSD / DPD? Are you familiar with H and P sentences, of the new pictograms?
I am concerned with the CLP transition in 2015?
If you are involved in chemical products in any capacity or at any level, the answer is likely to be: yes !
You must be compliant with CLP regulation if you manufacture, import, use or distribute chemical products. To sum up: the scope is extended to the entire chemical industry.
In concrete terms: what do I have to do from now until June 1, 2015?
You are a manufacturer or an importer:
- Check that you carry out the classification of your products using the new CLP regulation, and that you use an harmonized classification if it exists.
- Check that you provide to downstreams users SDSs and labels compliant with CLP classification.
- Check that you pack your mixtures in compliance with CLP regulation.
If yes: You are compliant!
If no: The next section of this article will be very helpful.☺
You are a downstream user or a distributor:
- Check labels on each of my product: are there the new pictograms?
- Check all Safety Data Sheets of my products: Are the classification information in CLP and not in DSD / DPD? Are the hazard information as H sentences? The safety advice as PF sentences?
- Check that you pack and label your mixtures according to CLP regulation.
If yes : You are compliant!
If no: The next section of this article will be very helpful.
How to succeed in your 2015 CLP transition?
Check your SDSs and labels compliance
You must make sure that your SDSs are compliant with CLP regulation. Indeed, REACH regulation requires that the 16 SDS mandatory sections in a SDS comply with the new CLP official procedure (pictograms, hazard classes, safety advice, etc...).You need to check that SDSs or all your products are written in accordance with the right procedure.
This work is tedious and time consuming but unavoidable. Tools are designed to help you in this task: please check our page Safety Data Sheets / CLP to get to know more, or contact us directly via contact@ecomundo.eu
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What do I do if some of my Safety Data Sheets are not compliant?
If you are manufacturer or an importer and if you create your own chemical mixtures on which the SDS is about, you are in charge of its classification. This step is explained in the following paragraph: « How to classify my substance or mixture?».
If you are a downstream user or distributor, chemical mixture suppliers must provide you SDSs in the right classification format. It is up to you to contact suppliers if the SDSs are not compliant and ask them compliant ones.
This work may be sensitive, especially when the number of SDSs is considerable. Some software solutions exist using a collect methodology that allows you to outsource this step. The ideal is to use a software management tool for Safety Data Sheets, like SDS Factory in order to stock and archive your information and easily disseminate them to your users.
Do not hesitate to contact us to know more about it !
How to classify my substance?
A substance classification is a key-step for data creation related to hazards. If there is no harmonised classification existing at an european level; it is complex procedure that must always go through the judgment of an expert ( It is called "auto-classification").
EcoMundo takes care to collect and create necessary data for classification, then have it designed and validated by one of our toxicological expert.
How to classify my mixture?
Mixture classification is calculated from its containing substances. Some chemico-physical characteristics are taken into account from the mixture (physical state, kinematic viscosity, flammability, etc.). Calculation rules are explained in Annexe I of CLP regulation.
SDS Factory is an automated calculation engine of CLP regulation for mixtures, which, from one chemical component of your mixtures it calculates CLP classification. To know more, do not hesitate to check our page, or directly contact us.
What can I do if some of my labels are not compliant?
According to CLP regulation, you need to go through all classification elements and print your labels that you must firmly attached on your product. Article 17 requires further conditions if a mixture is classified as dangerous.
Indeed, name, address, supplier(s) phone number and nominal quantity of the substance or mixture must be written on the packaging label when it is designed for mass-consuption (except if the quantity is specified somewhere else on the package). Further information are needed such as, product identifiers , hazard pictograms, relevant warning message, hazard message, appropriate precautionary statements and a section designed for further information. In case of non-conformity of some of your labels, you need to print them again.
To save time, you can, as well, use an IT-supported data acquisition for classification which, from mixture components can automatically define classification and directly print labels with all information required.
How can I notify my substance to ECHA?
You must submit a notification dossier to ECHA in XML or IUCLID 5.4 format. EcoMundo takes care of issuing and submitting the dossier.
What is the deadline for compliance?
The first deadline was in December 2010 and only substances were concerned. Nevertheless, a second deadline is in June 1, 2015 and concerns only mixtures. However, with the exemption system, you can get two more years. Thus, you had until December 1, 2012 for substances already on the market before December 1, 2010; If you have mixtures already launched on market before June 1, 2015, you are eligible for an exemption until June 1, 2017. By then, DSD / DPD system will have disappeared.
Be careful ! Double labelling is not allowed after June 1, 2015.
