SAFEGUARDS | Consumer ProductsNO. 110/21
On August 2, 2021, the World Trade Organization (WTO) announced a draft regulation from the European Union (EU) on its intention to revise Regulation (EC) 1272/2008 on Classification, Labeling and Packaging of Substances and Mixtures (CLP Regulation, consolidated version to May 2021). The draft legislation, attached to WTO document 21-6014 and notified under G/TBT/N/EU/626, contains several important changes. It:
- Adds 39 entries to Table 3 in Part 3 of Annex VI to the CLP Regulation ‘List of Harmonized Classification and Labeling of Hazardous Substances’ (Table 3), including bisphenol S (BPS, CAS 80-09-1) as a reprotoxic 1b substance
- Replaces 17 entries in ‘Table 3’, including new classification and labeling information for bisphenol A (BPA, CAS 80-05-7)
- Deletes one entry from ‘Table 3 – 1,5-naphthylene diisocyanate (CAS 3173-72-6)
According to the WTO notification, it is proposed that the draft regulation is:
- Adopted in Q4 of 2021
- To enter into force 20 days from publication in the Official Journal of the EU (OJEU)
- To become effective 18 months after the date of entry into force for the new harmonized classification, labeling and packaging provisions (potentially this is mid-2023)
Per the draft regulation, the changes in the amendment may be voluntarily applied from the date of entry into force.
Bisphenol S is an analogue of BPA and has increasingly been used as a functional replacement for this substance. It has a variety of applications, including curtains, flooring, footwear, furniture, leather, paper and cardboard products and toys.
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