From its entry into force, a series of provisions will be in place to manage the transition from the DSD/DPD Regulations to CLP. The key dates are summarised in the Table below:
|
Date |
Effect |
|
20th January 2009 |
CLP enters into force – Annex I of DSD repealed |
|
1st December 2010 |
Obligation to apply CLP to substances & update SDS |
|
3rd January 2011 |
Deadline for notification to the C&L inventory |
|
1st June 2015 |
Obligation to apply CLP to mixtures & update SDS |
The main differences between Directive 67/548/EEC (Dangerous Substances Directive, DSD) Directive 1999/45/EC (Dangerous Preparations Directive, DPD), which provided the previous classification and labelling rules, and the new rules that CLP has brought into force, are summarised in the Table below:
|
|
DSD/DPD |
CLP |
|
Terminology |
Preparation, Dangerous, Category of danger, Risk phrase (R), Safety phrase (S), Indication of Danger |
Mixture, Hazardous, Hazard class, Hazard statement (H), Precautionary statement (P), Signal Word* |
|
Criteria |
Categories of danger for physical, health and environmental hazards; Categories of danger plus additional labelling elements; Calculation rules for the classification of preparations; Testing, human experience or calculation for mixture classification |
Total number of hazard classes higher under CLP than the total number of categories of danger under DSD**; Hazard classes plus supplemental labelling elements from DSD**; Calculation methods deviating from the DPD calculation rules ***; Similar to DPD; includes principles to allow classification of mixtures from similarly tested mixtures |
|
Labelling |
DSD symbols; 50 different safety phrases |
CLP pictograms; 110 different precautionary statements |
|
Procedures |
Harmonised based on a MS proposal;
No notification procedure foreseen |
Harmonised based on MS proposal or a proposal by M/I/DU under certain conditions; Notification required to C&L inventory by January 2011 |
*UN GHS terminology; *UN GHS hazard classes; *** UN GHS calculation methods; M/I/DU: Manufacturer, Importer or Downstream User. Adapted from ECHA's 'CLP compared to DSD and DPD'.
The date from which classification and labelling must be consistent with the new CLP rules will be 1 December 2010 for substances and for mixtures 1 June 2015.
