In our last quarterly newsletter, we spoke about the CLP Regulation. This will require EU companies to update the Classification, Labelling and Packaging of their substances and mixtures over the next 5 years.

The key obligations under the CLP Regulation are as follows:

Key Dates

• From December 1st, 2010 substances must be classified in accordance with the CLP regulation.
• From June 1st, 2015 mixtures must be classified in accordance with the CLP regulation.
• A notification of the classification and labelling of substances must be made to ECHA for hazardous substances and substances subject to registration under REACH by December 1st, 2010.

2010 Obligations

Phase 1 of CLP will affect substances. Pure substances placed on the market will need to be classified, labelled and packaged in accordance with CLP.  The Safety Data Sheet for these pure substances will need to be updated with the new classification data.

A notification of the classification and labelling, CLP Notification, of substances will need to submitted to ECHA by EU manufacturers and importers for the following substances:

• Hazardous substance placed on the market regardless of the tonnage.
• Hazardous substance present in a mixture (placed on the market) above certain concentration limits which results in the classification of the mixture as hazardous.
• Substance subject to registration under REACH (>1 tonne per year).

Non EU manufacturers and formulators are not allowed to appoint an Only Representative to submit CLP notifications on their behalf. The EU importer has the obligation to comply with CLP notification. However, due to substance and product composition confidentialities, the EU importer will not always be in a position to comply.

H2 Compliance has a detailed CLP service from inventory analysis to CLP Classification, and finally to ECHA submission and SDS update.  We can also provide solutions to ensure that your EU importers will be able to comply with CLP notification obligations without revealing substance information.

For more information on our CLP service and solutions, contact a member of H2 Compliance.