CLP Basics

In the pre-CLP regime, there were fifteen danger classes; CLP comprises some twenty-nine hazard classes divided into three areas: physical, health and environmental hazards. Unlike previous systems, CLP’s hazard classes are sub-divided into categories with different criteria for classification.

For the physical hazards, CLP sees a move from five to sixteen hazard classes, introducing new hazard classes such as ‘corrosive to metals’. In doing so, it brings the classification for supply in line with the requirements for the transport of dangerous goods.

For health effects, a chemical previously classified as ‘harmful’ could be classified under CLP according to its acute toxicity, aspiration toxicity, specific target organ toxicity – single exposure (‘STOT SE’), or specific target organ toxicity – repeated exposure (‘STOT RE).

Notification to the C&L Inventory

The obligation to notify to the C&L Inventory applies to manufacturers and importers of substances placed on the EU market which are either:

• subject to registration under REACH, or
• hazardous and imported on its own, or
• imported in a mixture in concentrations leading to the classification of that mixture under CLP.

The notification must be submitted within a month of first placing the substance on the EU market.

Companies are also required to maintain their notifications and submit updates where new information leads to a change in classification. Notifiers and REACH registrants are also required to make every effort to come to an agreed classification where more than one has been submitted.

REACHReady’s Gold subscribers can find more detailed advice on how to manage their obligations on the CLP pages of our website. If you aren’t a Gold subscriber, contact us  to find out more. 

Dealing with mixtures under CLP

If you import or formulate and supply mixtures you must classify and, where required, label them to CLP before placing them on the market. Are you about to place on the market a new product? Or perhaps you have a new formulation to supply? If so, the first task will be to gather and assess information in order to classify your mixtures. Once classified to CLP, you may need to design your labels, with input of course from your marketing department!

All of these tasks require time and a budget. If you have the expertise and resources to do the work in-house you can find out more about how to classify and label at our next CLP workshop , visit our events page to find out more. Our Gold subscribers can also read our CLP guidance on the password-protected part of the REACHReady website to help them get started.

Alternatively, you may decide to outsource the work - why not let us to put you in touch with some suitable Approved Service Providers though our Matchmaker service. 

Poison Centres 

In 2017, a new Annex VIII was added to the CLP Regulation, implementing harmonised information requirements for notifications to poison centres. The main principle is that importers and downstream users placing hazardous chemical mixtures on the market need to submit information to the appointed body of the Member States where the mixtures is placed on the market. This information is then used for emergency health responses. 

Training

If you need to understand how the CLP Regulation including the new poison centre notifications affects your products and what you must do to comply, come along to one of our training days. We regularly run workshops which will provide an introduction to both REACH and CLP including poison centres – check out the training section of the website to find out more. Alternatively we can deliver bespoke training tailored to deliver just what you and your colleagues need to know about REACH and CLP in your own workplace or online via a webinar.