CLP Regulation

What is GHS & CLP?

 

CLP stands for the Regulation (EC) No 1272/2008 on the Classification, Labeling and Packaging of substances and mixtures. CLP introduces the United Nations globally harmonized system (UN GHS) for classification and labeling of chemicals into Europe. CLP entered into force on 20th January 2009. [Full text, pdf, 1.2MB]

 

There are many different systems for classifying and labeling chemicals in the world, which causes confusion, potential errors and misunderstandings among workers and consumers alike. This was primarily due to exposure to differing forms of labeling and safety data sheets in different countries. Thus, the United Nations developed a Globally Harmonized System for the classification and labeling of chemicals, known as GHS. As an international agreement GHS is non-legally binding in Europe, therefore the GHS criteria was introduced into Europe via CLP.

 

What does CLP mean for EU manufacturers and importers of chemicals?

  • A manufacturer, importer or downstream user of chemical substances or mixtures to be placed on the market, must classify, label and package these substances or mixtures in accordance with CLP, independently of the actual tonnage manufactured, imported or placed on the market;
  • Distributors (including retailers) of substances and mixtures need to label and package in accordance with CLP;
  • Substances must be classified and labeled in accordance with CLP by 3 December, 2010, or December 2012 if already on the market; Mixtures must be classified and labeled in accordance with CLP by 1st June, 2015, or 1st June 2017 if already on the market;
  • Manufacturers and importers (or groups of manufacturers or importers) who place a hazardous substance on the market, will also have to notify certain information, in particular the substance identity and the classification and labeling of that substance to ECHA before 3 Jan 2011, unless this information has already been submitted as part of a registration under REACH. ECHA will then include the notified information in the Classification & Labeling Inventory;

 

Which substances have to be notified to the C&L Inventory?

  • Substances subject to registration under REACH (>=1 tonne/year) and placed on the market, unless a supplier has already registered the substance with a classification and labeling according to CLP;
  • Substances classified as hazardous under CLP and placed on the market irrespective of the tonnage; and
  • Substances classified as hazardous under CLP and present in a mixture above the concentration limits specified in Annex I of CLP or as specified in Directive 1999/45/EC, where relevant, which results in classification of the mixture as hazardous, and where the mixture is placed on the market.

 

How to submit a CLP notification to the C&L Inventory?

C&L notifications will be submitted electronically via the REACH-IT system. The IT tools for notifications will be available in the first half of 2010. The following information is required for C&L notification:

  • your identity and the identity of substance;
  • the classification of the substance;
  • indication of why if the substance has been classified in some but not all CLP hazard classes;
  • if applicable, specific concentration limits, or M-factors related to the classification as hazardous for the aquatic environment together with a justification for the use; and
  • the labeling elements for the substance, including the supplemental hazard statements referred to in Article 25(1).

 

Companies will ultimately have three options for submission of CLP notifications:

  • via IUCLID 5.2
  • via an online form on ECHA¡¯s website designed especially for SMEs with reduced information notification needs
  • directly to REACH-IT using an xml form for bulk submissions

 

Note: There is no fee for making C&L notifications.

 

Do I have to notify to the C&L Inventory?

  • We have pre-registered several substances under REACH and we are not going to register them until 2018, do we have to notify to the C&L Inventory before 3 Jan 2011? Yes.
  • We place a hazardous substance on the EU market and we didn't pre-register/register them because our tonnage is lower than 1 ton per year. Do we have to notify to the C&L Inventory before 3 Jan 2010? Yes.
  • We bought products from a non-EU suppliers and the products will be registered by the Only Representative before Dec 2010, do we have to submit our own notifications before 3 Jan 2010? Yes.

 

What is the relationship between CLP and REACH?

The main link between REACH and CLP is that both contain hazard communication tools: labeling rules are set out in CLP whereas the Safety Data Sheet (SDS) rules are set out in REACH. Therefore, they cannot be used in isolation from each other. CLP introduces a number of changes to the SDS provisions in REACH. These come into effect over three different timelines between now and 2015. In addition, the notification requirements originally set out in REACH have been moved to CLP. Please click here for more information about your roles and obligations under REACH and CLP.

 

How can we assist you in complying with CLP?

We provide end-to-end solutions to CLP compliance. We can help you classify your substances and mixtures according to CLP, notify your classification and labeling to the C&L Inventory, print GHS labels and prepare the latest Safety Data Sheets.

  • Regulatory advice on the implications of CLP and REACH for your company;
  • Re-classification and re-labeling of your substances or mixtures;
  • Printing GHS labels;
  • Notification to the Classification & Labeling Inventory;
  • New Safety Data Sheets in accordance with CLP & REACH;

 

More Resources

 

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