Classification, Labelling and Packaging (CLP) Regulation (EC) No 1272/2008)
From 1st December 2010 a new regime for the classification, labelling and packaging will come into force. This new regulation replaces the Dangerous Substances Directive (DSD) and the Dangerous Preparations Directive (DPD) which are implemented in the UK as the CHIP Regulations. The CLP Regulation also takes over some aspects of the REACH Regulations.
What is affected
BTHA members may be affected if they place substances or mixtures on the market that meet the following requirements,.
- Substances subject to registration under REACH (over1 tonne/year) and placed on the market, unless a supplier has already registered the substance with classification and labeling according to CLP;
- Substances classified as hazardous under CLP and placed on the market irrespective of the tonnage; and
- Mixtures that contain a substance classified as hazardous under CLP and present above the concentration limits specified in CLP (or as specified in the DPD where relevant) which results in classification of the mixture as hazardous and where the mixture is placed on the market.
A ‘substance’ is a chemical element and its compounds in the natural state or obtained by a manufacturing process. (These may include preservatives that protect their stability or impurities derived from the process. However, it excludes any solvent which may be removed without affecting its stability or changing its composition.)
A ‘mixture’ is a mixture or solution composed of two or more substances. These were formerly known as ‘preparations’.
The CLP Regulation summary of impact:
• Change in the classification of hazardous substances and mixtures.
• Changes to hazard warning symbols.
• Changes the standard warning phrases and the format of Safety Data Sheets.
• Suppliers of dangerous substances must notify the European Chemicals Agency (ECHA) by December 2010.
Timeframe
In the UK, amendments to the CHIP regulations (CHIP 4) allow the new CLP Regulation to be aligned with the existing requirements during a transitional period. This transition period will mean that substances must be re-labelled before December 2010 but mixtures can be re-labelled any time before June 2015. This will result in a confusing period where both systems are being used and this is expected to confuse consumers and retailer alike.
Full details of the transition period are outlined below.
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Substances |
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20th January 2009 – 1st December 2010 |
Suppliers must classify substances according to CHIP, and may continue to label and package them according to regulations 6 to 11 of CHIP. However they may as an alternative choose to classify, label and package substances according to CLP. In this case, they must in addition |
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1st December 2010 – 1st June 2015 |
Suppliers must classify substances according to both CHIP and CLP. They must label and package according to CLP. |
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1st June 2015 onwards |
Suppliers must classify, label and package according to CLP. |
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Mixtures (Preparations) |
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20th January 2009 – 1st June 2015 |
Suppliers must classify mixtures according to CHIP, and may continue to label and package them according to regulations 6 to 11 of CHIP. However they may as an alternative choose to classify, label and package mixtures according to CLP. In this case, they must continue to classify in addition under regulation 4 of CHIP, but the requirements on labelling and packaging in regulations 6 to 11 of CHIP no longer apply. |
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1st June 2015 onwards |
Suppliers must classify, label and package according to CLP. |
BTHA members who think that they supply a substance or mixture covered by the new CLP Regulation should seek further advice at:
• Health and Safety Executive - www.hse.gov.uk/chip/index.htm
• REACHReady - www.reachready.co.uk
• European Chemicals Agency - echa.europa.eu/clp/clp_help_en.asp
