Classification, Labelling and Packaging Regulation – CLP Regulation
General | Legislation | Technical | CLP Label | Further Information |
What is CLP?
The ‘CLP’ Regulation (EC) No 1272/2008 on the classification, labelling and packaging of substances and mixtures, or simply ‘CLP’, introduces the United Nations globally harmonised system (UN GHS) for classification and labelling of chemicals into Europe.
The benefits of CLP are multiple:
- It provides a single classification and labelling system in the EU and worldwide
- It reduces compliance costs associated with the numerous current systems and by facilitating international trade
- It ensures more consistent hazard classification and communication leading to better health, safety and environmental protection
- It supports and improves the information flow up and down the chemical supply/use chain
Why is CLP needed?
It was widely recognised around the world that the many different systems for classifying and labelling chemicals was causing confusion, potential errors and misunderstandings among workers and consumers alike. This was primarily due to exposure to differing forms of labelling and safety data sheets. Thus, the United Nations developed a globally harmonised system for the classification and labelling of chemicals, known as ‘GHS’. As an international agreement GHS is non-legally binding in Europe, therefore the GHS criteria was introduced into Europe via CLP.
When does CLP come into force?
CLP came into force on 20th January 2009 and is direct acting in all Member States. It will fully apply following an 8 year transitional period, thus allowing enterprises time to changeover from the existing rules. (See 2.1 for implementation in Ireland).
When do I need to comply with CLP?
There is a phased transitional period which will allow enterprises time to change over from the existing rules. Substances must be classified and labelled in accordance with CLP by 1st December, 2010, or December 2012 if already on the market, and likewise for mixtures must classified and labelled in accordance with CLP by 1st June 2015 or 1 June 2017, if already on the market. However CLP can be introduced before these deadlines.
Who does CLP apply to?
CLP will apply to suppliers of substances and mixtures (preparations) and for anybody that has to apply the new rules for classification, labelling and packaging under CLP. Suppliers are manufacturers of substances, importers of substances or mixtures, downstream users, including formulators (manufacturers of mixtures) and re-importers, and distributors, including retailers, placing on the market substances or mixtures.
What is the relationship between CLP and REACH?
The main link betweenREACH and CLP is that both contain hazard communication tools: labelling rules are set out in CLP whereas the Safety Data Sheet (SDS) rules are set out in REACH. Therefore, they cannot be used in isolation from each other. CLP introduces a number of changes to the SDS’s provisions in REACH. These come into effect over three different timelines between now and 2015. In addition, the notification requirements originally set out in REACH have been moved to CLP. (See SDS FAQ’s)
What is the relationship between CLP and GHS?
GHS is implemented in Europe through the CLP Regulation 1272/2008 . CLP is based on the 2nd edition of the UNGHS (July, 2007). The United Nations Sub-Committee of Experts on the Globally Harmonized System of Classification and Labelling (UNSCEGHS) was established in 2001 to implement the UNGHS worldwide. It reports directly to the UN Economic and Social Council (ECOSOC). It has bi-annual meetings, in which the HSA participates. The 3rd Edition of the UNGHS ‘purple book’ was published in July 2009. This 3rd edition will require a future adaptation (ATP) to the CLP Regulation. The UNSCEGHS are now working on revising the 3rd edition.
What happens with the existing CPL Regulation?
The existing European Classification and labelling Directives, namely 67/548/EEC and 1999/45/EC are transposed in Ireland by means of the following Statutory Instruments:
- S.I. 116 of 2003 for substances and its amendments (1, 2) (implements Directive 67/548/EC).
- S.I. 62 of 2004 for preparations and its amendments (1, 2) (implements Directive 1999/45/EC).
CLP amends Directive 67/548/EEC through Article 55, most notably Annex I is deleted and its entries transferred to Annex VI, Table 3.2 of CLP and also translated to CLP criteria in Annex VI, table 3.1. Likewise, CLP also amends Directive 1999/45/EEC through Article 56. The Irish Statutory Instruments listed above will be consolidated to incorporate these amendments in the near future. Directives 67/548/EEC and Directive 1999/45/EC will eventually be repealed and these transposing ‘Statutory Instruments’ will be revoked.
How is CLP enforced in Ireland?
CLP is direct acting in all Member States. In Ireland, it will be brought under the ambit of the Chemicals Act for administrative and enforcement purposes.
The Health and Safety Authority and the Pesticide Control Service are designate Competent Authorities covering industrial chemicals and pesticides/biocides respectively. These Competent Authorities are expected to be formally appointed through an amendment to the Chemicals Act by the end of 2009.
How will CLP be amended?
As with all legislation, CLP will not remain static and will be amended following updates such as to the Harmonised Classification and Labelling list and future developments at UN GHS level.
The first amendment to CLP has already been agreed in March 2009. This was through an Adaptation to Technical Process (ATP), which was needed to transfer the harmonized classifications contained in the 30th and 31st ATP to Annex I to Directive 67/548/EEC into CLP due to the fact that Annex I to Directive 67/548/EEC was deleted when CLP entered into force on 20th January 2009. This ATP will take the form of a Regulation and, therefore, be directly applicable throughout the EU. It will come into force 20 days after publication in the Official Journal (OJ). It is anticipated that it will apply from 1 December 2010.
What is new in CLP?
CLP brings us a single ‘direct acting’ Regulation, introduces new ‘global’ classification criteria for both substances and mixtures, global rules for labelling along with other new elements that are carried over from the existing CPL rules or from REACH such as the requirement to notify substances, (Article 40), a Helpdesk function, (Article 44), requirement for a Poison Centre (Article 45), coordinated enforcement activities, (Article 46) etc.
What are the main changes with CLP?
CLP introduces a new ‘global’ terminology. The main changes in terminology are outlined in the table below with the label elements being expanded further...
|Hazard Statement||Risk Phrase|
|Precautionary Statement||Safety Phrase|
|Signal Word ( Danger/Warning)||Indication of Danger ( e.g. Irritant)|
|Annex VI||Annex I|
Part 1: Pictograms (Articles 19 & 26)
- Hazard Pictograms:The familiar orange hazard symbols are replaced by hazard pictograms in the shape of a square set at a point, with a white background and red border
- CLP also introduces three new hazard pictograms; the ‘Exclamation Mark’ which will replace primarily the St Andrews Cross, the ‘Exploding Man’ which is to be used to identify chronic health hazards and ‘gas bottle’ used to identify compressed and liquefied gases.
- Signal Word:There will no longer be an ‘indication of danger’ such as ‘Toxic’ or ‘Dangerous to the Environment’, instead CLP introduces two signal words ‘Warning’ or Danger’ depending on the category of the hazard class.
Part 2: Hazard statements (Articles 21 & 27)
Hazard (H) statementswill replace Risk (R) Phrases for example H317 ‘May cause an allergic skin reaction’ replaces R43 ‘May cause sensitization by skin contact’. Unlike the existing CPL codes the ‘CLP’ codes they are grouped depending on the hazards so more user friendly.
- H200-H299 Physical hazard H222 ‘Extremely flammable aerosol’
- H300-H399 Health hazard H317 ‘May cause an allergic skin reaction’
- H400-H499 Environmental hazard H400 ‘Very toxic to aquatic life’
Part 3: Precautionary statements (Article 22 & 28)
Precautionary (H) statements will replace Safety (S) Phrases for example P102 ‘Keep out of reach of children’ replaces S2 ‘keep out of reach of children’. Unlike the existing CPL codes they are grouped depending on their purpose so again easier to use.
- General P102 ‘Keep out of Reach of Children’
- Prevention P201 ‘Obtain special instructions before use’
- Response P310 ‘Call a poison centre’
- Storage P410 ‘Store in a well ventilated place’
- Disposal P501 ‘Dispose of container to…’
Part 4: Supplemental information: (Article 25)
This comprises of a number of elements, including the following
(a) EU Leftovers;these hazard classes are not included in the GHS but were retained in CLP (See Annex III. Part 2 & Annex VII, Table 3.2)
- EUH001 (R1) ‘Explosive when dry
- EUH066 (R66) ‘ Repeated exposure may cause skin dryness or cracking’
- EUH059 (R59) ‘Hazardous to ozone layer
(b) Special Rules: which were taken over from the existing CPL Regulations (see Annex II)
- EUH201/201A Contains Lead Should not is used on surfaces liable to be chewed or sucked by children. Warning contains lead
- EUH202: Cyanoacrylate. Danger. Bonds eyes and skin in seconds. Keep out of reach of children
- EUH204: Contains Isocyanates. May produce an allergic reaction
(c) Other information can be provided in the ‘supplemental information section provided it does not contradict or cast doubt on validity of the information specified elsewhere on the label
What does a CLP label contain?
CLP Article 17 sets out the ‘general rules’ that apply to the label. It comprises of the name, address, telephone number of the supplier, product identifiers and where applicable, hazard pictograms, signal word, hazard statements, precautionary statements and supplemental information. To ensure that customers can easily take notice of the hazard information on packages, general rules are set out to determine the colours, size of labels, formats, legibility and location of label elements. The supplier may choose the order of the hazard and precautionary statements but they must be located together and be in an official language of the Member State unless the Member States state otherwise. As an example, please find below a label for Acetone:
Danger, Highly flammable liquid and vapour. Causes serious eye irritation. Repeated exposure may cause skin dryness or cracking. May cause drowsiness or dizziness.
Keep out of reach of children. Store in a well-ventilated place.
Keep away from heat/sparks/open flames/hot surfaces. No smoking. IF IN EYES:
Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do.
Continue rinsing. Immediately call a POISON CENTER or doctor/physician.
IF SWALLOWED: Rinse mouth. Immediately call a POISON CENTER or doctor/physician.
Where can I obtain further information on CLP?
CLP Helpdesk: 1890 289 389 or email firstname.lastname@example.org
CLP Webpage: http://www.hsa.ie/eng/Sectors/Chemicals/GHS_CLP/
REACH/CLP E-Bulletin: http://newsweaver.ie/hsa/index000306244.cfm
Introduction to CLP Presentation Introduction to CLP.pdf (size 3 MB)
ECHA FAQ’s on CLP http://echa.europa.eu/doc/classification/questions_and_answers_clp_20090526.pdf
CLP Industry Guidance ECHA Website - Classification
Industry Guidance on CLP will be available shortly at the following link: http://echa.europa.eu/classification/clp_guidance_en.asp
Institute for Health and Consumer Protection: Classlab http://ecb.jrc.ec.europa.eu/classification-labelling/search-classlab/
CLP EU Conference on CLP 17th June, can be downloaded to view http://ec.europa.eu/enterprise/reach/information/events/index_en.htm
United Nations Sub-Committee on GHS: www.unece.org/trans/danger/publi/ghs/ghs_welcome_e.html