Classification Labelling & Packaging
Position of Unico regarding CLP.
CLP
A new regulation on Classification, Labelling and Packaging (CLP) of substances and mixtures became effective on 20th January 2009.The CLP regulation implements the UN Globally Harmonised System of Classification and Labelling of Chemicals (GHS) into EU legislation. Harmonised international rules aim to improve the protection of human health and the environment and to facilitate international trade with chemicals.
The European Chemicals Agency (ECHA) will be the host of the official classification and labelling inventory. After 1 December 2010 manufacturers and importers will be obliged to report their classification to the inventory. All substances within the scope of CLP that are classified as hazardous must be reported to the inventory. In addition, substances registered according to the REACH regulation must also be reported. If the information has already been sent to ECHA as part of a full registration according to REACH, it need not be reported again.
Regulation (EC ) No.1272/2008 on classification, labelling and packaging of substances and mixtures will supersede the EU substance 67/548/EEC and preparation 1999/45/EC directives. To allow companies to adopt the new regulation there will be a transitional period during which both old and new classification can appear on the label and the safety data sheet.
Table 1 contains information on the rules and the dates.
Differences
A new feature of CLP is that criteria and test methods for physical hazard (explosive, flammable and oxidising properties etc) are in accordance with the regulations on transport for dangerous goods.
The black danger symbols on an orange square background do not appear in CLP. The CLP symbols (pictograms) are placed on a white diamond background.
Indications of danger included in the labelling like Harmful or Irritating are not included in CLP. Instead the signal words Hazard and Warning apply.
Exemptions
Radioactive substances and mixtures.
Substances and mixtures which are subject to customs supervision.
Non-isolated intermediates.
Substances and mixtures for scientific research and development which are not placed on the market.
Waste
In the interests of defence.
Medicinal products, veterinary medicinal products.
Cosmetic products.
Medical Devices.
Food or feeding stuffs.
Table 1
Date | Rules Apply | |
Before 1 December 2010 | Substances must continue to be classified, labelled and packaged in accordance with DSD. However a substance may also be classified, labelled and packaged according to CLP before this date. If so, the labelling and packaging provisions of DSD shall no longer apply to the substance. | If a substance is classified, labelled and packaged according to CLP, the CLP classification must appear on the Safety Data Sheet, alongside the classification based on the DSD. However a supplier may choose to identify the CLP classification of a substance in advance of applying CLP to it in full. Where this happens the supplier may include this information on the accompanying Safety Data Sheet under the other information heading. |
Before 1 December 2010 | Mixtures must continue to be classified according to DPD. However a mixture may also be classified, labelled and packaged according to CLP before this date. When this is done, the labelling and packaging provisions of DPD shall no longer apply to the mixture. This means that labelling and packaging must respect the provisions of CLP. | The classification of a mixture according to DPD must be provided in the Safety Data Sheet. If a mixture is classified, labelled and packaged according to CLP, the CLP classification must appear on the Safety Data Sheet alongside the classification based on the DPD. However a supplier may choose to identify the CLP classification of a mixture in advance of applying CLP to it in full. Where this happens the supplier may include this information on the accompanying Safety Data Sheet under the other information heading. |
After 1 December 2010 | Substances must be classified in accordance with both DSD and CLP.
Substances must be labelled and packaged in accordance with CLP only, but substances already classified, labelled and packaged according to DSD and placed on the market (i.e. on the shelves) before 1 December 2010 will only have to be re-labelled and re-packaged by 1 December 2012. | Until 1 June 2015 the classification of a substance according to DSD must be provided in the Safety Data Sheet, in addition to the CLP classification. This will apply to Safety Data Sheets for substances on their own and to Safety Data Sheets for mixtures containing these substances. |
After 1 December 2010 | Until 1 June 2015, mixtures must continue to be classified, labelled and packaged in accordance with DPD. However a mixture may also be classified, labelled and packaged according to CLP before this date. When this is done, the labelling and packaging provisions of DPD shall no longer apply to the mixture. This means that labelling and packaging must respect the provisions of CLP. | Until 1 June 2015, the classification of a mixture according to DPD must be provided in the Safety Data Sheet. Until 1 June 2015, if a mixture is classified, labelled and packaged according to CLP, the CLP classification must appear on the Safety Data Sheet alongside the classification based on the DPD. However a supplier may choose to identify the CLP classification of a mixture in advance of applying CLP to it in full.where this happens the supplier may include this information on the accompanying Safety Data Sheet under the other information heading. |
After 1 June 2015 | Substances must be classified in accordance with CLP only. | Substance classification according to CLP must be provided on the Safety Data Sheet. |
| Mixtures must be classified, labelled and packaged in accordance with CLP only. Mixtures already classified, labelled and packaged in accordance to DPD and placed on the market ( on the shelves) before 1 June 2015 will only have to be re-labelled and re-packaged by 1 June 2017. | Mixture classification according to CLP must be provided on the Safety Data Sheet. |
