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Europe’s CLP Regulation – Overview, Deadlines and Fees

Europe’s new-ish CLP Regulation on classification, labeling and packaging of chemicals is getting a lot of buzz all of a sudden.  Also called just CLP, it entered into force on 20 January 2009.  CLP regulation will take companies from the current classification and labeling directives to the globally harmonized system of chemical classification or GHS.  CLP is not just an idea, it is a new requirement for doing business in Europe.

CLP aspires to facilitate global trade and to promote regulatory efficiency with a harmonized communication system around hazardous chemical-substances.  Further, CLP complements the Registration, Evaluation, Authorization and Restriction of Chemicals  or REACH Regulation.

CLP is based on United Nations’ GHS

The new CLP regulation is based on the UN GHS for a globally harmonized system of classification, labeling for chemicals. For more on GHS, see Top Ten Q&A about GHS.  Not all at once but over time, the CLP regulation will replace the Dangerous Substances Directive or DSD and the Dangerous Preparations Directive or DPD currently in place; both Directives will be repealed on 1 June 2015.

The CLP Regulation as published in the Official Journal of the European Union is available at the EURLEX website, the official web site of the European Law online journal.

For U.S. companies, CLP means certain substances will be more severely classified and more mixtures will be classified.  Also, it means companies may have to reclassify, re-label and repackage products, along with making changes to current Safety Data Sheets or updating SDS; also, a change of classification under CLP may lead to new responsibilities under REACH.  An analysis of your company’s current conditions is advised.  It’s likely that at least minor adjustments are in order.

CLP timeline and key deadlines

The CLP transitional provisions contain key dates that affect the classification and labeling of hazardous chemicals, substances and mixtures.  Spend a few moments with the graphic accompanying this article.

As with the previous legislation, the CLP Regulation is intended to be primarily a self-classification system for enterprises.  Key deadlines for CLP compliance include:

1. 30 November 2010:  Substance classification (according to the CLP rules)

2. 31 May 2015:  Mixture classification (according to the CLP rules)

    The obligations due by these dates — such as changes to Safety Data Sheets — as well as their relationship to the REACH deadlines — are illustrated in the graphic, which is courtesy of European Chemicals Agency.

    CLP fees

    NEW: Fees are payable to ECHA under CLP.  ECHA sees two fees for two types of requests:

    • EUR 12000: harmonized classification and labeling under CLP article 37
    • EUR 4000 and up: confidentiality/use of alternative chemical name for substances in mixtures under CLP article 24

      Small to Medium Sized companies or SMEs can benefit from reduced fees up to 90%, depending on size. More information on fees is  online here (see Annex I and II).

      ECHA advises companies to submit substance data in timely manner

      The EU CLP places new legal obligations on companies operating in the EU. By 1 December 2010, companies are required to classify and label their hazardous substances according to the CLP rules.  Industry must post substances placed on the market to a central database, called the Classification & Labeling Inventory. The database will be established and maintained by ECHA.

      On September 10, the European Chemicals Agency estimated that the number of CLP notifications will be in the millions; ECHA advised companies preparing for CLP: “please notify in time.”

      ECHA says:

      • The first deadline for notification is 3 January 2011.
      • Key information from this Classification and Labeling Inventory will also be made publicly available on ECHA’s website.
      • Confidential business information will not be disclosed to the public.

      Guidance

      This Guidance is developed to assist primarily manufacturers or importers applying classification and labeling criteria and it also includes practical examples. It is also assumed to be the guidance on classification and labeling for Competent Authorities in the Member States, Commission services and European Chemicals Agency (ECHA). In certain chapters, such as the chapters on carcinogenicity, mutagenicity and reproductive toxicity, the guidance includes more extensive scientific advice on how to interpret different data used for classification.

      Complete guidance doc

      CLP guidance overview and Frequently Asked Questions about CLP

      This article is reprinted by permission from Kathleen Hurley, executive producer of the Actio Communications Network. Actio is a Portsmouth, NH based technology company whose mission is to provide software tools for product stewardship functions such as chemical management and supplier disclosure risk management in an era of REACH, RoHS and Green Chemistry.

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