A key difference is that the final product as presented to the consumer is excluded, not the entire supply chain. For example, in the case of a cosmetic product, CLP labelling on the final packaging on the store shelf is not required. however, the previous production and bulk supply phases fall within the scope of the CLP Regulation and the hazard communication requirements set out in the Regulation apply. In 2017, a new Annex VIII was added to CLP, implementing harmonised information requirements for notifications under Article 45. This information is transmitted to the notified bodies of the Member State and used for emergency medical measures (poison control centres). A mixture consists of two or more substances and is subject to the same requirements as the constituent substances. The CLP Regulation sets thresholds for each type of hazard above which this hazard must also apply to the mixture. Note that most of these thresholds must be per component, and some are additive (meaning actors must add all components with this threat). Many mixtures contain dozens, if not hundreds, of components, and special software can make calculations easier. CLP enables the identification of hazardous chemicals and the communication of these hazards to users through labelling. It also forms the basis for safety data sheets (SDS), which are regulated by the REACH Regulation, and sets out the requirements for the packaging of hazardous chemicals. The Classification, Labelling and Packaging (CLP) Regulations are an implementation of the United Nations Globally Harmonized System (GHS).

The GHS provides a harmonized system for hazard classification, product labelling and other aspects such as safety data sheets (SDS) in all regions and signatory countries. The GHS uses a modular approach that allows regions to incorporate different requirements into local legislation. The SDS must include a publication date, version number, and revision information. Annex II of the CLP provides further details on SDS requirements. Importers or downstream users placing mixtures presenting a risk to human health on the EU market must submit notifications from the Poison Control Centre (PCN) to an organisation designated by the Member State concerned. The information requirements for these notifications are set out in Annex VIII to the CLP Regulation. The information transmitted shall be retained for access by national poison centres for emergency medical response, where prompt access to clear information on hazardous mixtures is essential. Depending on the Member State, stakeholders can submit notifications via ECHA`s submission portal or directly to the Member State.

The CLP Regulation lays down detailed criteria for label elements: pictograms, signal words and standard hazard, prevention, reaction, storage and disposal statements for each hazard class and category. It also establishes general packaging standards to ensure the security of supply of hazardous substances and mixtures. In addition to communicating hazards through labeling requirements, CLP is also the basis for many chemical risk management regulations. The National Poisons Information Service (NPIS), also known as the National Poison Centre, is the receiving authority under GB CLP. If you are a UK-based importer or downstream user of a hazardous mixture, the information can be emailed to NPIS in the form of a safety data sheet. Submissions under GB CLP are voluntary. This also applies to NI-based companies that supply qualified NI products (QNIGs) directly to the UK market. Annex VI to CLP lists substances that have a harmonised classification. Any Member State, manufacturer, importer or downstream user can propose a harmonised classification within the EU. It is up to the Committee for Risk Assessment (RAC) of the European Chemicals Agency (ECHA) to evaluate these proposals.

Although this method can be used for any hazard, it is generally used for the most serious hazards (carcinogenicity, mutagenicity, reproductive toxicity and respiratory sensitizers). Once approved and adopted, the details of the harmonised classification will be included in Annex VI of CLP, resulting in additional requirements. Certain types of products are exempted from the classification and labelling requirements of CLP as they are subject to their own separate legislation with the same rigour. As the GHS is a voluntary agreement and not a law, it must be adopted through an appropriate national or regional legal mechanism to ensure that it becomes legally binding. This is what the EU CLP Regulation does. The CLP Regulation applies to your business when you manufacture, import, use or distribute chemicals or mixtures on the EU market. Compliance with the new EU regulation on product safety classification, notification and labelling is required for most substances, regardless of quantity and use. Compliance with CLP requirements is a prerequisite for access to the EU market and must be taken into account by your company alongside the demanding REACH deadlines that companies already face in the EU market. Main CLP deadlines: The CLP Regulation (classification, labelling and packaging) is a piece of European Union legislation introduced in 2008 that applies to the European Economic Area (EEA). The Regulation is the European Union`s system for classification, labelling and packaging of chemicals and adopts the Globally Harmonised System (GHS). The GHS is a non-legally binding international agreement of the United Nations for the classification and communication of hazardous properties of industrial and consumer chemicals.

The GHS has replaced various regulations used around the world. The STG can help identify all the labeling requirements required by CLP. The CLP Regulation establishes the same legally binding requirements in all Member States of the European Economic Area (EEA). CLP requires all importers, manufacturers and downstream users to properly classify, label and package substances and mixtures before they can be placed on the market. TSG can help you determine your company`s CLP requirements for chemicals and mixtures within the EEA. CLP requires manufacturers, importers or downstream users of substances or mixtures to classify, label and package these products before placing them on the market. This requirement ensures that hazard information is shared effectively throughout the supply chain. To ensure that all information on the label is easily visible, the following size requirements apply: Product labelling allows for clear hazard communication throughout the supply chain. Users of the substance or mixture shall be informed of any hazards and may take all appropriate risk management measures. The legislation establishes detailed labelling requirements, including pictograms and wording, label size and legibility, appropriate packaging standards, and the presentation and content of SDSs, an essential part of the hazard communication process to be used in the workplace. Intertek provides global expertise in helping companies identify their CLP obligations and prepare notification dossiers for submission to ECHA. Intertek also offers comprehensive reporting support, as well as a strategy and training module to help organizations meet CLP compliance requirements.

Once a substance or mixture has been classified, all risks must be effectively communicated to your customers.