Compliance date for industrial use only mixtures – 1 January 2024

From 1 January 2024, all newly notified products that are available on the European market will have to comply with requirements of Annex VIII to the CLP Regulation. The deadline applies to importers and downstream users of industrial use only mixtures that are classified as hazardous according to the EU CLP Regulation. Other hazardous mixtures should already have been notified to the poison centers earlier.

 

How do industrial use only mixtures differ from those for professional use?

Industrial use only mixtures are exclusively used at industrial sites and are not available to consumer or professional users either as a final product or in diluted form through reformulation.

If your product is, for example:

  • a raw material that is further formulated into a professional or consumer type product, or
  • an undiluted material which is diluted at industrial site to create a product further sold to consumers/professionals

it should be considered as a product with professional/consumer use.

The compliance date for notifying professional and consumer products to the Poison centers was in 2021 and all notifications of such products should follow the Annex VIII requirements.

 

Transitional period

For products which have already been notified to the Poison centers through the national submission systems, there is a transitional period until 1 January 2025.

If any modifications are made to the products during the transitional period, which would require updates of the existing notifications, such updates should be carried out in the harmonized format as required by Annex VIII to the CLP, even before 1 January 2025.

 

Information requirements

The harmonized information requirements of Annex VIII to the CLP Regulation include:

  • full chemical composition
  • toxicological information
  • information about the product
  • unique formula identifier (UFI)

However, for industrial use mixtures there is an option of making a ‘limited submission’ using the compositional information from the Safety Data Sheet. If this option is used, the notification must include a contact person who can provide around the clock rapid access to the complete compositional details in case of an incident.

 

Unique formula identifier (UFI) in the notification and the label

All hazardous mixtures requiring a notification must have a UFI in both the PCN notification and on the product label so that poison centers can link the product to the submitted data. However, if a hazardous mixture is used exclusively at an industrial site, the UFI may be indicated in Section 1.1 of the Safety Data Sheet only and not on the label. If the same mixture is available also for consumer or professional users, the UFI is required on the label to ensure the safety standard for those users.

 

You are welcome to get in touch to discuss this further and see how the requirement applies to your product portfolio.