- We want to improve the way we communicate with you
- Classification and labelling under CLP
- HelpNet provides harmonised answers to REACH and CLP questions
- The busy years of risk assessment starting
- The chemical industry in the EU Economy
- The Technical Completeness Check plug-in is now available
- ECHA 2009 review and outlook
- Head of Unit appointed for the new Registration and Dossier Submission Unit
- Risk management – choose the best option!
- Realistic information and help in relocation promote well-being
- EVA Expat Forum asked foreign professionals about their life in Finland
Send your feedback to:echanewsletter (at) echa.europa.eu
Article related to: CLP
Classification and labelling under CLP
The ECHA Newsletter is publishing articles on the practical implementation of classification and labelling under CLP, with regard to the 1 December 2010 deadline.
Phil Todd is an expert on European classification and labelling issues in Syngenta, one of the world's largest agrobusiness companies. The company supplies crop protection products, seeds and seed treatments throughout the world and has manufacturing sites in Europe, North America, South America and Asia. It also imports into all regions, including Europe. Mr Todd was interviewed in December on the occasion of ECHA's Stakeholders' Day where he was a speaker.
|Phil Todd spoke about classification and labelling at the Stakeholders' Day in December 2009.|
How far are you with CLP classification and labelling?
The total amount of substances and mixtures that we have to reclassify lies in the region of several hundreds. We are coming towards the end of our planning phase. We have spent this year working on identifying what needs to be done by when and have created an implementation organisation. Next year we will concentrate on making system changes to handle the new labelling data, re-labelling our substances and preparing for the classification and labelling inventory. In addition, we will work on communicating the new requirements to those affected together with suitable training. We have already started to prepare the classification of our substances and mixtures and have made substantial progress.
Do you encounter specific problems in relation to classification and labelling according to CLP?
Having worked with GHS for a number of years prior to CLP, the technical aspects of reclassification are fairly straightforward. What is more difficult is to explain the new text and pictograms to the people who have to use the classifications.
Will your company notify substances before the first deadline, 3 January 2011?
At the moment it is too early to say. There are still too many uncertainties about the practical process to be able to make a clear judgement about how we are going to address this issue. For example, the tools to notify are still not available but I understand that they should be available during early 2010. Our plan for notification currently assumes the use of the bulk upload facility. However the technical specifications for the file format and the working processes relating to bulk uploads are not available from ECHA yet. This means that the add-on to our classification database is not yet available from our software supplier and therefore we cannot plan with any certainty for when we could implement the tool or indeed, whether the tool will be as useful to us as we hope it will be.
Are there other topics in relation to classification and labelling relevant for your company?
For crop protection companies in general, one of the issues that needs to be resolved is the interaction between CLP and regulation 1107/2009, the new Regulation on Plant Protection Products. The issue is that the CLP labelling elements are a small part of the label for a crop protection product. Under regulation 1107/2009, the label has to be submitted to and approved by the national regulator for plant protection products.
On the other hand, the CLP regulation clearly states that classification is the responsibility of the supplier. The requirements of CLP and the Plant Protection Products Regulation can be achieved by an understanding amongst both companies and regulators that the label approval process under the Plant Protection Products Regulation does not include the CLP labelling elements and that these remain the responsibility of the company.
What would you ask of ECHA if you had one wish?
My main wish would be for ECHA to make rapid progress towards resolving the outstanding implementation issues for which it has responsibility. For example, companies need clarity on many aspects of the operation of the C&L inventory in order to plan how they will notify to it. Additionally, the process by which the Risk Assessment Committee comes to a classification opinion is still not completely clear. We acknowledge that progress has been made in the past few months but would need further clarity. It is important to industry that the classification opinion is credible and to achieve this, it must be the result of a process that is open, transparent and based on sound science.
What is your general impression of the implementation of CLP in your business sector? Are there specific problems?
The initial internet consultation suggested that the transition period for substances would be in the order of 3-4 years. In reality, this has turned out to be less than two years. Considering that many of the one-off changes also have to be made during this period, hindsight is already indicating that a transition period in line with the original suggestion would have been more realistic. It will be challenging to meet the 2010 deadlines.
In the Crop Protection sector, we do need to resolve the issue of the interaction between CLP and the Plant Protection Products Regulation. Not only does this have direct impact on the detailed timetable for reclassifying our mixtures, it is also critical for ensuring that the aims of CLP are realised i.e. one product has the same classification in all countries in Europe. I suspect that many readers will be surprised to know that, under the current Dangerous Preparations and Plant Protection Products directives, one product may not have the same classification in all countries in which it is sold despite the suppliers desire to have only one classification.
Sign in to comment and/or rate this article.
Biocidal Products Committee:
26 February-1 March
Committee for Risk Assessment:
6-8 March and
Committee for Socio-Economic
Management Board meeting:
23-27 March (tentative)
Member State Committee:
20-24 April (tentative)