Does Your Mixture Need to be Relabeled According to CLP from June 1, 2017?
The Classification, Labeling and Packaging (CLP) Regulation ensures that chemical hazards are clearly communicated through the classification and labeling of chemicals so that consumers and workers are informed about their effects before they handle them.
The legislation also provides the basis for safety data sheets (SDSs) that are regulated under REACH and defines requirements for the packaging of hazardous substances. Before substances and mixtures (formerly preparations) are placed on the market, the industry must establish potential risks to human health and the environment, and classify them with identified hazards.
What is CLP?
In the European Union (EU), the CLP Regulation is governed by Regulation (EC) 1272/2008 on classification, labeling and packaging of substances and mixtures. The Regulation was adopted from the United Nations’ Globally Harmonized System (GHS) on the classification and labeling of chemicals and has replaced two pieces of legislation, Directive 67/548/EEC (Dangerous Substances Directive, DSD) and Directive 1999/45/EC (Dangerous Preparations Directive, DPD). The CLP entered into force in January 2009 and has applied to all member states of the European Union (EU) since June 2015. Due to new scientific data on chemicals and technical development, the CLP Regulation is routinely amended by adaptations to technical progress (ATPs).
In CLP, the principles for classification and labeling are similar to DSD and DPD but the criteria for classification are different. Pictograms are used for health hazards, physical-chemical hazards and environmental hazards (Table 1). The signal word is either ‘danger’ or ‘warning’. There are also hazard statements (H statements) and precautionary statements (P statements).
Table 1. CLP Pictograms
Relationship Between CLP and SDSs
An SDS should be provided to downstream users for:
- A substance or mixture that is classified as hazardous to CLP
- A substance that is persistent, bioaccumulative and toxic (PBT) or very persistent and very bioaccumulative (vPvB)
- A substance on the Candidate List of substances of very high concern (SVHCs)
Implementation of CLP
The CLP Regulation was implemented in a two-phase transitional period. It has applied in full to substances placed on the market since December 1, 2012 and to mixtures placed on the market since June 1, 2015. Mixtures that have been classified, labeled and packaged according to DPD and placed on the market before June 1, 2015 must be relabeled and repackaged according to the CLP Regulation from June 1, 2017.
Impact of CLP on Companies
Suppliers of chemicals are required to classify, label and package substances and mixtures in accordance with the CLP Regulation. The obligations are dependent on the role of suppliers in the supply chain. Suppliers may have one or more of these roles:
- Manufacturer of substances or mixtures
- Importer of substances or mixtures
- Manufacturer of specific articles
- Downstream user, including formulators and re-importer
- Distributor, including retailer
Elements of the CLP Hazard Label
- Name, address and telephone of supplier(s)
- Nominal quantity package made available to the general public
- Product identifier
- Hazard pictogram where applicable
- Signal word
- Hazard statement where applicable
- Precautionary statement where applicable
- Supplementary information
Legislation and Standards Where CLP Regulation Has An Impact
- Directive 2009/48/EC on Toy Safety (TSD). For example, substances classified as carcinogenic, mutagenic or reprotoxic (CMRs) Category 1A, 1B or 2, unless exempted, are prohibited
- REACH. For example, substances classified as CMRs Category 1A or 1B are prohibited to be supplied to the general public (entries 28 to 30 under Annex XVII)
- Regulation (EC) 10/2011 on ‘Food Contact Plastics’. CMRs should not be used without previous authorization
- EN 71-4 ‘Experimental sets for chemistry and related activities’
- EN 71-5 ‘Chemical toys (sets) other than experimental sets’
Products where CLP Has An Impact
- Aerosol dispensers and adhesives/glues
- Ink in pens
- Food contact plastics (substances classified as CMRs should not be used without previous authorization)
- Toys that are articles (CMRs are prohibited)
- Toys that are substances or mixtures such as accessible liquids in writing instruments, bubble solutions, crayons, finger paints, play dough and slime.
Customizable, to meet your needs and budget, our services include CLP labeling, safety data sheets (SDSs) to REACH and international requirements, consultancy and factory audits, among others.
For further information about SGS CLP and CLP-related services, contact your local representative or our global expert.
Global Information and Innovation Manager
SGS Hong Kong Limited
t: +852 2774 7420