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Päivi Jokiniemi and Paul Trouth
Article related to: CLP
Classify and label your mixtures in time
From 1 June 2015, the Classification, Labelling and Packaging (CLP) Regulation will be the only legislation that applies to the classification and labelling of both substances and mixtures in the EU. For now, the Dangerous Preparations Directive and its national implementing legislation is still in force, but CLP takes over from 1 June 2015 onwards. The CLP Regulation has applied in fact to substances since 1 December 2010 but now, mixtures come into play. The CLP Regulation implements the Globally Harmonised System (GHS) that has been agreed in the United Nations (UN).
CLP requires companies to classify, label and package their hazardous chemicals appropriately before placing them on the market. Its purpose is to ensure a high level of protection of health and the environment, as well as the free movement of substances, mixtures and articles. Using the UN pictograms and labels that are understood throughout the world will contribute to the more consistent communication of hazards and reduce companies' costs when importing or exporting chemicals.
Manufacturers and importers of substances are already used to classifying and labelling their substances in accordance with the CLP Regulation. For formulators, the situation is different. An enormous number of mixtures sold to industrial clients must be re-classified and re-labelled to comply with CLP. In addition to industrial mixtures, consumer products such as paints or detergents are also affected.
What is new?
The obligations for companies placing chemicals on the market under the CLP Regulation are basically similar to those under the Dangerous Preparations Directive. However, there are some important differences, both in the classification rules and in the labelling.
The most visible labelling change is the replacement of the old square orange symbols by pictograms with white diamonds and red borders. Be careful – although the new symbols within the pictograms may be similar to the old ones, there is not necessarily a one-to-one relationship between them. In addition, three new pictograms have been introduced (the exclamation mark, gases under pressure and the human silhouette).
|An enormous number of products must be re-classified and re-labelled to comply with CLP. Image: ECHA.|
The new standardised hazard and precautionary statements which replace the old risk and safety phrases respectively are also visible on the label. The methods for selecting the appropriate statements have also changed to improve the communication to consumers on safe use, storage and disposal.
The CLP Regulation also introduces new hazard classes for classification. These are, for example, gases under pressure and corrosive to metals. For some hazard classes, the concentration limits or the criteria for determining the category have also been changed. This can potentially result in a more severe classification for the same mixture or in the mixture being classified when it was not before.
The obligation to use the CLP rules from 1 June 2015 does not mean that the old orange squares will disappear immediately. Products that are already labelled, packaged and on the market by 1 June 2015 can still be sold for two years and do not have to be re-labelled and re-packaged until 1 June 2017.
How do I classify mixtures under CLP?
1. Bring together all the information you have on your mixture (and substances contained in the mixture) and assess its validity. Sources of information may include in-house information, the safety data sheet and ECHA's classification and labelling inventory.
2. Evaluate the information against the criteria for classification and work out the new classification for the mixture. This may require some technical expertise because in most cases it is not appropriate to make a quick conversion from the old classification to the new one. Note that the calculation methods for some hazard classes have been modified. The concentration limits at which classification is needed may also have changed.
The CLP Regulation and other support material are available on ECHA's website. New mixture classification pages lead you through the steps of the classification process. There are also useful links to further information such as the guidance on the application of the CLP criteria, which contains more detailed instructions on how to fulfil your obligations. We recommend that, even if you have experience in classification, take a look at the pages to see what may have changed under CLP.
New ‘bridging principles' may also be helpful if you do not have data on the mixture itself, but you have data on similar tested mixtures. The guidance on the application of CLP criteria explains the conditions under which the bridging principles may be applicable and gives simple examples on their use.
Do not forget to check the composition of all your mixtures – even those that did not have a classification under the previous directive – they may need to be classified now.
3. Finally, you need to re-label your mixture with revised information and update the safety data sheets that you provide to your customers. Any new mixture that enters the market after 1 June 2015 must be classified, labelled and packaged in accordance with the CLP Regulation.
Still got questions?
On 16 September, the European Commission and ECHA will organise a joint workshop in Brussels on the safe use of chemicals. The workshop aims to find out what challenges companies, in particular SMEs, face when complying with the CLP Regulation and to try to identify possible solutions. You can register to attend the workshop on the European Commission website until 26 August.
If your questions are not answered on ECHA's website, you can also contact the ECHA Helpdesk.
There is no need to wait until 1 June 2015 to apply the rules of the CLP Regulation: act now and make sure that your mixtures are classified and labelled in time.
- CLP Legislation
- Guidance on CLP
- CLP 2015 page
- Leaflet: Classifying and labelling chemicals
- Mixture classification pages
- C&L inventory
- ECHA Helpdesk contact form
- European Commission website for the workshop
Text by Jos Mossink
Top image: Three new pictograms.
The obligation to use the CLP rules as of 1 June 2015 does not mean that the old orange squares will disappear immediately. Products that are already labelled, packaged and on the market by 1 June 2015 can still be sold for two years and do not have to be re-labelled and re-packaged until 1 June 2017. Image: ECHA.
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Biocidal Products Committee:
26 February-1 March
Committee for Risk Assessment:
Committee for Socio-Economic
18-22 March (tentative)
Management Board meeting:
Member State Committee:
13-17 May (tentative)