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CLP Regulation in full effect

September 10th, 2015

The Classification, Labelling and Packaging Regulation (CLP; Regulation (EC) 1272/2008) has been in force since January 2009. On 1st June 2015 it came into full effect. The previous legislation, the Dangerous Substances Directive (DSD; Directive 67/548/EEC) and Dangerous Preparations Directive (DPD; Directive 1999/45/EC), are now repealed.

CLP is the European Union implementation of the United Nations’ Globally Harmonised System of classification and labelling (GHS). Its purpose is to standardise the clear communication of hazard information about substances to users, including consumers and industrial and professional users. It achieves this by defining the criteria on which the intrinsic hazardous properties of substances should be assessed. It also sets out the requirements for labelling and packaging and associated Hazard and Precautionary Phrases. Hazardous properties are characterised by ability to cause adverse effects to human health and to the environment, or intrinsic physical/chemical hazards.

The practical implication of the legislative change is that all remaining mixtures will require re-classification based on the CLP Regulation, something the downstream users will also need to be aware of. It has been obligatory to include substance classification based on the CLP scheme in REACH dossiers since December 2010, but classification using the DSD/DPD system could previously still be used for the purpose of classifying mixtures, which must now be removed.

In addition to setting out hazard criteria and labelling and packaging requirements, CLP includes tables of “harmonised classifications”. These are classifications which have been agreed by the European member states and enforced in law by inclusion of Annex VI of CLP. Annex VI and the CLP Regulation itself, are periodically updated by Adaptations to Technical Progress (ATPs), which take into account developments in knowledge and understanding of the assessment of hazards and of the hazards of specific substances. The globally harmonised system of classification and labelling (GHS) has been fully implemented by the EU, however the implementation amongst other UN members remains variable.

PFA has years of experience in providing expert advice in matters relating to classification and labelling. The ECHA searchable CLP inventory can be found here.