CLP Regulation

CLP or CLP Regulation stands for Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures, amending and repealing directives 67/548/EEC and 1999/45/EC, and amending Regulation (EC) No 1907/2006 (REACH). It came into force on 20 January 2009 and applies across the European Union. The legislation introduces throughout the EU a new system for classifying and labelling chemicals, based on the United Nations’ Globally Harmonised System (UN GHS).

Obligations of a manufacturer or importer under CLP

You should classify, label and package substances and mixtures according to CLP Regulation before placing them on the market. You should also classify substances not placed on the market that are subject to registration or notification in line with Articles 6, 9, 17 or 18 of REACH (CLP Article 4)

You should classify in line with CLP Title II (CLP Articles 5-14)

You should label in line with CLP Title III (CLP Articles 17-33)

You should package in line with CLP Title IV (CLP Article 35)

You should notify the classification and labelling elements to the classification and labelling inventory established at the ECHA in case you place substances on the market (CLP Article 40)

You should take all reasonable steps available to you to make yourself aware of new scientific or technical information that may affect the classification of the substances or mixtures you place on the market. When you become aware of such information which you consider to be adequate and reliable you should, without undue delay, carry out a new evaluation of the relevant classification (CLP Article 15)

You should update the label following any change to the classification and labelling of that substance or mixture, in certain cases without undue delay (CLP Article 30)

If you have new information which may lead to a change of the harmonised classification and labelling elements of a substance (Part 3 of Annex VI to CLP) you should submit a proposal to the Competent Authority in one of the Member States in which the substance is placed on the market (CLP Article 37(6))

You should assemble and keep available all the information required for the purposes of classification and labelling under CLP for a period of at least 10 years after you have last supplied a substance or mixture. This information should be kept together with the information required in Article 36 of REACH (CLP Article 49)

I MISSED THE NOTIFICATION DEADLINE OF 3 JANUARY 2011, WHAT SHOULD I DO?

For hazardous substances and substances with a registration deadline in 2013 or 2018, which are placed on the EU market on or after 1 December 2010, the deadline for notification to the inventory is one month after you have placed them on the market for the first time. If you missed this deadline, notify without delay. This is a legal obligation and you may be faced with action by the national enforcement authorities if you do not comply.

You may get more information about your obligations under CLP Regulation at ECHA website.