Classification, Labelling and Packaging (Regulation (EC) No. 1272/2008, CLP)
If you manufacture or import a chemical substance (or mixture) into the EU you will be affected by the new rules for the classification, labelling and packaging of chemicals (CLP). CLP places obligations on manufacturers/importers to (re)classify and (re)label all substances and mixtures. In addition, manufacturers/importers of substances (on their own or in mixtures) were required to notify the GHS classifications of their substances to ECHA by the 3rd Jan 2011. For more information contact ReFaC now.
If you are unsure about your obligations or need assistance with achieving compliance ReFaC can help. We offer the following services to our customers:
- Regulatory consultancy on the implications of CLP for your business
- Timelines for compliance
- Identification of your obligations under CLP and development of compliance strategies
- Comparative analyses of your obligations under CLP as compared to other relevant legislation (i.e. REACH)
- Re-classification of substances or mixtures
- Re-labelling of products
- Notification to C&L inventory (if not already performed)
Safety Data Sheets
From 1 December 2010, Annex II of REACH is replaced by Annex I of Regulation (EC) No. 453/2010 (also known as the first amendment to Annex II). Annex I details changes to the format and content of the SDS to be implemented. Furthermore Annex II will be updated again in June 2015 (second Revision to Annex II) to reflect the need for inclusion of CLP classifications for mixtures.
As such there are a number of relevant deadlines for compliance with the revisions to Annex II:
- 1 December 2010; the SDS for substances must use the first revision to Annex II after this date. The SDS for new mixtures must use the first revision to Annex II after this date.
- 1 December 2012; The SDS for all mixtures must be compliant with the first revision to Annex II.
- 1 June 2015; The SDS for all substances and mixtures must use the second revision to Annex II.
- 1 June 2017; The SDS for mixtures ‘on the shelf’ must be re-issued with one in accordance with Annex II.
At any point in this process a SDS may be required to be updated in accordance with Article 31(9) of REACH. This situation occurs when new information on risk management measures (RMMs) or hazards (i.e. new classification) becomes available, when authorisation is granted/refused or a restriction is imposed.
In addition, REACH places an obligation on any actor in a supply chain who is required to prepare a Chemical Safety Report (CSR) to provide details of the exposure scenarios in an annex to the SDS (creates an extended SDS or eSDS). Preparation of the eSDS requires review of the CSR and collation of the relevant information into a format appropriate for use in an eSDS.
ReFaC can assist with all aspects of SDS from preparation to managing obligations. We can offer the following services which can be tailored to meet your needs:
- Regulatory consultancy on the timelines affecting the SDS of your substances
- Management of your portfolio of substances to ensure compliance with the relevant legislation
- Preparation of SDS in the required format
- Review of CSRs and preparation of the eSDS
For more information or for a detailed quotation tailored to your individual requirements, contact ReFaC now.
