The CLP Regulation, requires companies to classify, label and package their chemical substances according to the new CLP criteria as of 1 December 2010. The classification and labelling information must also then be notified to the European Chemicals Agency (ECHA) where it will be included in the Classification and Labelling Inventory. The first deadline was last 3 January 2011.
Why do we need the CLP Regulation?
One of the main purposes of CLP is to introduce the United Nations’ Globally Harmonised System (GHS) for classifying and labelling chemical substances and mixtures within the EU. The CLP Regulation ensures harmonised communication of the hazards of chemicals for workers and consumers. Thus it will have a positive impact on occupational and public health as well as on the environment. An additional key benefit for enterprises is that international trade of chemicals will be easier, as the standards for transporting and supplying chemicals across the world will be the same. Finally the classification and labelling Inventory, which will include classification and labelling information on substances placed on the EU market, will be publicly available on ECHA’s website in 2011.
Who should notify?
Duties to notify under the CLP Regulation arise for any company placing substances on the market and carrying out one of the following activities:
- manufacturing or importing substances subject to registration under REACH
- manufacturing or importing substances classified as hazardous, irrespective of the quantity concerned
- importing mixtures containing hazardous substances, irrespective of the quantity, when the mixture is classified due to the presence of the substance
- importing articles containing substances which are subject to registration under REACH
Notifications are only possible by manufacturers and importers based in the EU. Non-EU companies can nominate one of their importers to notify on behalf of all the others.
Although downstream users do not need to notify, they nevertheless have the obligation to classify, label and package substances and mixtures in line with CLP prior to placing them on the market. For those receiving a substance or mixture from another actor in the supply chain (providing no change is made to it), the can take up the classification already supplied by that actor. In cases where changes are made to substances, this triggers the individual need to classify in line with CLP.
We think that this post throws some light of the subject, don’t you?. For more information, please go to ECHA website.