From 1 June 2015, the Classification, Labelling and Packaging (CLP) Regulation will be the only legislation that applies to the classification and labelling of both substances and mixtures in the EU. For now, the Dangerous Preparations Directive and its national implementing legislation is still in force, but CLP takes over from 1 June 2015 onwards. The CLP Regulation has applied in fact to substances since 1 December 2010 but now, mixtures come into play. The CLP Regulation implements the Globally Harmonised System (GHS) that has been agreed in the United Nations (UN).
CLP requires companies to classify, label and package their hazardous chemicals appropriately before placing them on the market. Its purpose is to ensure a high level of protection of health and the environment, as well as the free movement of substances, mixtures and articles. Using the UN pictograms and labels that are understood throughout the world will contribute to the more consistent communication of hazards and reduce companies’ costs when importing or exporting chemicals.
Manufacturers and importers of substances are already used to classifying and labelling their substances in accordance with the CLP Regulation. For formulators, the situation is different. An enormous number of mixtures sold to industrial clients must be re-classified and re-labelled to comply with CLP. In addition to industrial mixtures, consumer products such as paints or detergents are also affected.
What is new?
The obligations for companies placing chemicals on the market under the CLP Regulation are basically similar to those under the Dangerous Preparations Directive. However, there are some important differences, both in the classification rules and in the labelling.
The most visible labelling change is the replacement of the old square orange symbols by pictograms with white diamonds and red borders. Be careful – although the new symbols within the pictograms may be similar to the old ones, there is not necessarily a one-to-one relationship between them. In addition, three new pictograms have been introduced (the exclamation mark, gases under pressure and the human silhouette).
The new standardised hazard and precautionary statements which replace the old risk and safety phrases respectively are also visible on the label. The methods for selecting the appropriate statements have also changed to improve the communication to consumers on safe use, storage and disposal.
The CLP Regulation also introduces new hazard classes for classification. These are, for example, gases under pressure and corrosive to metals. For some hazard classes, the concentration limits or the criteria for determining the category have also been changed. This can potentially result in a more severe classification for the same mixture or in the mixture being classified when it was not before.
The obligation to use the CLP rules from 1 June 2015 does not mean that the old orange squares will disappear immediately. Products that are already labelled, packaged and on the market by 1 June 2015 can still be sold for two years and do not have to be re-labelled and re-packaged until 1 June 2017.