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Article related to: CLP
CLP mixtures deadline – feedback from the detergent and maintenance product industry
Mixtures being placed on the EU market had to be reviewed by 1 June 2015 according to the Classification, Labelling and Packaging (CLP) Regulation. This meant more safety information for the users of the products but new challenges for mixture manufacturers. We spoke with Dr Sylvie Lemoine from the International Association for Soaps, Detergents and Maintenance Products (A.I.S.E.) to find out about how industry managed.
Did companies manage to update the classification and labelling of their products in time?
Yes, most of A.I.S.E.'s member companies managed to re-label their products in time, with large companies reaching close to full compliance with the deadline. The two-year transition period, allowing products placed on the market before 1 June 2015 to still be labelled according to the former Directive, helped us to reach a high level of compliance. This means that products already ‘on the shelves' (meaning ‘in the supply chain') can be sold with their old labels and do not need to be recalled or wasted. This is particularly useful for slow-moving goods.
However, for small and mediumsized companies, the outcome was more diverse. Companies with many labels to update and limited resources, or those producing for other brands (for example private labels) faced particular difficulties.
Companies had to find additional staff to manage the deadline. In some cases, this meant redeploying staff within their company. This has led to a reduced number of new product launches, which is the main economic driver for our sector.
What were the main challenges?
As CLP has generally introduced more severe classification criteria and more classification endpoints, products that have previously not needed classification, have had to be classified.
Optimising workload and supply chain management has been a considerable challenge because of production constraints due to demand in our fast-moving consumer goods sector, and lack of clarity on how to manage stocks due to diverging interpretations of ‘placing on the market' in different countries.
All of our members also said that there was a lack of classification information from the suppliers or that if the information existed, it was delivered too close to the 1 June deadline and could no longer be taken into account when relabelling the products.
The new requirements for labelling different packaging layers and managing inner package labelling were quite laborious to implement. Some companies had to integrate other regulatory requirements such as the Biocidal Products Regulation at the same time and update their safety data sheets with the new information. Producers of laundry unit doses had to rush to implement new manufacturing, labelling and packaging requirements with the same deadline as CLP relabelling.
SMEs in particular reported that designing labels with more text as well as the selection of precautionary statements was often a burden. Resources were tight as companies were coordinating the generation of new labels while producing products and, at the same time, trying to meet the deadline.
Another aspect was explaining the label changes to retailers and clients. This was in particular difficult when the label changed and more severe classification applied, but the product formulation stayed the same. Some customers did not want to accept the new labels.
What is next for your sector in the classification and labelling of mixtures?
Reviews and updates are already foreseen as new information becomes available. This applies in particular for new classifications of the raw materials for mixtures.
With REACH leading to new data generation, companies will need more frequent updates in the coming years than was the case under the Dangerous Preparations Directive. In some cases, the classification updates will have far-reaching consequences, for example inclusion of new sites in the scope of the Seveso Directive for the management of majoraccident hazards.
Upcoming harmonised reporting to poison centres and the introduction of a unique product identifier will be another significant change to manage at company level, and will require relabelling.
In addition, there are still some uncertainties on the horizon, such as the understanding of the new pictograms by consumers, the classification and labelling of products with extreme pH values and explaining and implementing CLP in non-EU countries where the same packaging and labelling may also be used.
What were the lessons learnt from the point of view of the detergent and maintenance product industry?
Some of the new CLP requirements that were considered ‘relatively minor' when CLP was introduced, turned out to have a major impact. Comparing the actual costs to the cost-benefit analysis that was done at the early stage of CLP would be interesting.
In addition, harmonising definitions and requirements between the different legislation as well as clarifying interpretations of the law at EU level (for example placing on the market and the bridging principles) would have helped to reduce misunderstandings and workload. Industry is still facing too many national divergences of interpretation, which adds uncertainty to an already complex situation. Multiple labelling requirements from multiple pieces of legislation should also be revisited in particular concerning the labelling of ingredients.
To manage the upcoming changes in classification and labelling, companies should maintain very clear processes and tools with product lists and stock management.
As for the regulators, my message is clear: there needs to be three compliance deadlines for any future change impacting classifications – one for substances, one for intermediary mixtures (also called mixtures in mixtures) and one for end-use mixtures.
Dr Sylvie Lemoine is the Director of technical and regulatory affairs at A.I.S.E, which is the voice of the Soaps, Detergents and Maintenance Products industry in Europe. A.I.S.E.'s membership totals 31 national associations, covering about 900 companies ranging from small and medium-sized enterprises to large multinationals. Biocidal products manufactured by A.I.S.E. members include a vast range of disinfectants for household and institutional use, as well as household insect control products. http://www.aise.eu.
- CLP Regulation
- CLP pictograms and quiz
- A.I.S.E. website
- Dangerous Preparations Directive
- Terminology – in 23 languages
Text by Adam Elwan and Sylvie Lemoine
Top image: Sylvie Lemoine photographed by ECHA
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