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Editor-in-chief:
Johanna Salomaa-Valkamo

Editor:
Päivi Jokiniemi

Article related to: CLP

CLP 2015 – the deadline is approaching

On 16 September, the European Commission and ECHA held a workshop in Brussels to discuss the challenges faced by industry in complying with the requirements for the classification, labelling and packaging of mixtures. ECHA Newsletter met with two company representatives to get their perspective.

The classification, labelling and packaging (CLP) provisions have applied for substances already since 2010, but for mixtures, which represents the vast majority of products on the market, these will only become compulsory from 1 June 2015. The number of products that must be re-labelled is enormous, including both consumer items, such as paints or detergents, and industrial mixtures.

Make your partners aware

Ms Isabelle Demoment, the Regulatory Affairs Manager at HYPRED, gives an insight to the complexity of CLP on their day-to-day operations. "At HYPRED, we have set up a task-force to make sure that all the departments are fully engaged and aware of the strategic and tactical implications of the CLP Regulation". The task-force activities deal with the design and management of products, processes, services and supply chains. "The very first step for any strategic decision depends on classification. In light of the next CLP deadline, we have started already some time ago a massive reclassification exercise of all our chemicals," she points out.

As HYPRED is placed in the middle of the supply chain, they both receive information and have to provide information to others on the safe use of chemicals. To better support the information needs of their customers, HYPRED has provided training for their sales force. "But proving training and updated communication for our staff is not enough for us. We are also envisaging an awareness raising campaign to make our extended network of commercial partners fully aware of the CLP implications for their daily work."

Ms Demoment appreciates the clarity of ECHA's web pages on the classification of mixtures, even if the rules to apply for environmental classification need to be clearer. "We also use the CLP Inventory as a reference although, in our opinion, the different self-classifications for the same substance notified by industry make this tool somehow controversial," she concludes.

Take action now

The possibility to share experience at EU level and to discuss the challenges related to CLP with the EU Regulator was appreciated by Cristobal Bernal, Technical Manager at CARINSA. "I believe that it is of utmost importance for SMEs to have the opportunity to share experience and best practice so that they can find simple practical solutions to their problems," he says.

CARINSA is currently busy updating the IT information system that manages the labelling of its products. "The main challenge for us is to correctly manage the relevant CLP information," he says and continues, "the correct CLP labelling of a mixture made of several raw materials in different languages is a complicated piece of work. In some cases, the space available on the surface of the packaging may be very small compared to the information that we have to make available on the label. We are currently studying viable solutions".

In Mr Bernal's experience, companies that are selling or producing mixtures are still struggling to cope with the requirements of CLP. He strongly advises SMEs to join their national industry associations to stay updated and cope with the regulatory challenges. "Europe has made us use our chemicals safely. However, I would like to see SMEs more actively involved in all the discussions around the implementation of the regulations in our sector".

Further information:

CLP 2015 web pages

Companies

HYPRED is a member of the French Roulier group. They produce and market hygiene and detergent solutions for professionals in the agriculture, food and cosmetics sectors.

CARINSA is a Spanish based multinational group of companies specialised in flavours and fragrances for all kinds of products. CARINSA is a member of PIMEC, which represents the employers of micro, small and medium-sized enterprises as well as the self-employed workers of Catalonia.