The arrival and implementation of REACH over the last few years has somewhat eclipsed another related Regulation regarding the Classification, Labelling and Packaging of chemical substances and mixtures (CLP).
The CLP Regulation came into force in January 2009 and was first implemented on 1st December 2010. It will ultimately replace the Dangerous Substances/Preparations Directives.
Although broadly similar in approach to the Dangerous Substances Directive and the Dangerous Preparations Directive, CLP has introduced different classification thresholds, new hazard categories and statements, new precautionary statements (substituting the former R/S-phrases) and new pictograms. In addition the REACH regulation established a new format for the reporting of hazards in Safety Data Sheets. Manufacturers and importers of substances and the formulators of mixtures therefore need to reassess the classification of their products and make changes to the Safety Data Sheets and labelling where required.
In order to allow an orderly transition from DSD/DPD to CLP, the implementation was required over two phases.
Since 2010, manufacturers and importers of chemical substances have been required to:
- Notify the classification of hazardous substances (or substances subject to REACH) to the ECHA classification and labelling inventory.
- Classify and label substances according to CLP
- Provide a Safety Data Sheet with the classification according to CLP alongside the (older) classification according to DSD.
Since 2010, the classification of mixtures under CLP has not been mandatory and hence the requirements of both CLP and the Dangerous Preparations Directive have run side by side. However, in less than one year, at 1st June 2015, the final implementation of CLP is due. This second deadline will affect many smaller companies who formulate or import mixtures.
From 1st June 2015, the following new rules will apply:
- Substances must be classified according to CLP only
- Mixtures must be classified, labelled and packaged according to CLP only. (Companies will have 2 years to sell mixtures already classified, labelled and packaged according to DPD and placed on the market before 1st June 2015.)
- Safety Data Sheets for both substances and mixtures must provide the classification according to CLP
It is clear that the number of mixtures which will need to be reclassified and relabelled will be huge. With the deadline now so close, many formulators and importers of mixtures should already have their implementation plans well advanced, especially where new classifications will result in changes to labelling to take account of the new hazard pictograms.
Formulators and importers who have not yet taken action to implement CLP are urged to do so now. The following steps are recommended as a guide:
- Identify your role under CLP. (Do you have to re-classify your products or are your suppliers responsible?)
- Identify the products that need (re-)classification. (Use the classification under DSD/DPD as a start.)
- Decide whether you will undertake the classification yourself or will you need expert help.
- Understand what else will need to be changed eg Safety Data Sheet, labelling, packaging.
For those who have yet to get started, help is at hand, from one of the consultancy companies who specialise in CLP and who can work with you to classify mixtures, prepare safety data sheets and propose labelling solutions.
Graeme Towell
Senior Project Manager
Dr. Knoell Consult Ltd
