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Classification and Labelling

How does the 2008 CLP Regulation affect your products?  Is your labelling CLP compliant?

The CLP Regulation (Regulation (EC) No 1272/2008) is the new European Regulation on Classification, Labelling and Packaging of chemical substances and mixtures (preparations). It introduces into the EU new criteria for classification and labelling, based on the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (UN GHS).

 

A comprehensive worldwide harmonised system was required as countries have different rules on classification and labelling - a chemical could be classified as ‘toxic’ or ‘explosive’ in one jurisdiction but not in another.  There was also a lack of consistency with use of symbols, with different symbols being used to indicate the same hazards. However, as GHS is based upon a 'building block' approach, countries are permitted to select criteria they consider the most appropriate (e.g. China C&L). In the EU, the criteria chosen are those that most closely match the DSD and DPD systems. So it is important to bear in mind that this may result in different classifications for some products in the EU compared to other parts of the world.


In the EU, the CLP Regulation entered into force on 20th January 2009. This Regulation will replace Directive 67/548/EEC (Dangerous Substances Directive) relating to the classification, packaging and labelling of dangerous substances, Directive 1999/45/EC (Dangerous Preparations Directive) relating to the classification, packaging and labelling of dangerous preparations, as well as amending Regulation (EC) No 1907/2006 (REACH). The CLP Regulation contains 7 Titles and 7 Annexes.


The 7 Titles contain provisions on Classification, Labelling, Packaging, the CLP inventory and enforcement :

Title I      General Issues
Title II     Hazard Classification
Title III    Hazard Communication in the Form of Labelling
Title IV    Packaging
Title V     Harmonisation of Classification and Labelling of Substances and the Classification and Labelling Inventory
Title VI    Competent Authorities and Enforcement
Title VII   Common and Final Provisions


The 7 Annexes contain the information requirements for C&L, list of hazard and precautionary statements, list of harmonised C&L for substances, hazard pictograms and translation table from DSD to CLP.

Annex I      Classification and Labelling Requirements for Hazardous Substances and Mixtures
Annex II     Special Rules for Labelling and Packaging of Certain Substances and Mixtures
Annex III    List of Hazard Statements, Supplemental Hazard Information and Supplemental Label Elements
Annex IV    List of Precautionary Statements
Annex V     Hazard Pictograms
Annex VI    Harmonised classification and labelling for certain hazardous substances
Table 3.1: List of harmonised classification and labelling of hazardous substances
Table 3.2: The list of harmonised classification and labelling of hazardous substances from Annex I to Directive 67/548/EEC

Annex VII   Translation table from classification under Directive 67/548/EEC to classification under this Regulation

 

What is the relationship between REACH and CLP?


The CLP Regulation and REACH Regulation have several similarities and differences. The primary aim of both is to ensure the safe manufacture, import and use of chemicals throughout the EU. However, there is no tonnage band threshold with the CLP Regulation; if a substance or mixture in any quantity is hazardous, it must be labelled and packaged appropriately. Substances alone, or substances in mixtures or article that reach the 1 tonne per annum threshold must be registered under REACh.

The method of hazard communication in the supply chain also differs between REACH and CLP. REACh requires a Safety Data Sheet, compiled according to Annex II of the Regulation. CLP requires labelling, with CLP pictograms and precautionary statements.

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A. GHS compliance activities in China

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C. Compliance requirements for China new chemical substance notification

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