Classification, Labelling and Packaging (CLP, legislation 1272/2008/EU) is the EU’s adoption of the UN GHS. It is a chemical regulation that seeks to protect human health, ecosystems and the environment whilst maintaining worldwide trade.
Background to harmonisation of world chemical regulation
Awareness existed that different countries classified the same chemical in different ways. These differences were not conducive to world trade. Stemming from differences in classification, different labelling applied for each country/jurisdiction – each of varying severity.
Over the years, the United Nations have developed harmonised criteria for classification and labelling of dangerous/hazardous chemicals. The result was called the Globally Harmonised System of Classification and Labelling of Chemicals (UN GHS):
Following over a decade’s work by professionals all over the globe with expertise in such matters as fire safety and toxicology, a Committee of Experts approved the system and it was fully published.
CLP is based on previous hazardous chemical legislation within the EU (the Dangerous Substances Directive (DSD) and the Dangerous Preparations Directive (DPD). The biggest difference is that CLP is the implementation of a world standard (GHS) within the EU.
The CLP Regulation is legally binding across the EU Member States. It is directly applicable to industry. After the year 2015, CLP will overrule DSD and DPD. Currently there is a transitional period in place in the EU. As things stand (November 2012), the Dangerous Substances Directive has become obsolete. Neat and hazardous substances placed on the market must be classified, labelled and packaged in accordance with CLP.
Preparations containing hazardous chemicals placed on the market (now known as mixtures – of non-reacting chemicals) can still be placed on the market in compliance with the DPD or CLP.
However, from the middle of 2015 onwards the former legislation becomes obsolete; but after that a two year window is applied for companies to sell any stock that was classified, labelled and packaged in accordance with DPD. This retains marketability and allows companies to prosper, thus keeping within the spirit for which these three EU regulations discussed here lie.
Other aspects taken into account in CLP
The principle aim of CLP is to determine whether a substance or mixture displays properties that lead to a classification of being hazardous. As soon as the classification of a chemical is known, these hazards need to be communicated amongst all actors in the supply chain, along with consumers.
During hazard evaluation, information about the intrinsic properties of a substance or mixture is assessed to determine their potential to cause harm. Lab and animal tests are performed on each chemical in order to assess if a hazardous classification applies. For mixtures, a threshold limit is set up; such that if a mixture contains greater than a defined percentage of the hazardous substance, then the overall mixture will also carry that classification. These percentages vary depending on the classification.
H2 Compliance has dedicated staff to deal with CLP issues – whether it is for non-EU companies wishing to sell a hazardous product here (importers), or companies already based in the EU who are selling hazardous products here (manufacturers).
We also offer consultancy on such matters, and amongst our staff we have senior toxicologists who have carried out audits on premises for CLP compliance personally.
Initial stages of CLP compliant SDS or label delivery include an assessment of the ingredients of your product to determine if a hazardous classification exists. A Non-Disclosure Agreement (NDA) is signed to protect any proprietary information. The end product can usually be delivered to you within ten working days.
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