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Transitional Period

There is a phased transitional period to allow enterprises time to changeover from the existing rules. The first deadline, which applies to substances only, is the 1st December 2010, by which time all substances must be classified and labelled in accordance with the CLP rules. However, if a substance is already on the market on the 1st December 2010, this deadline is extended until December 2012.

The second deadline begins as the other ends and applies to mixtures only, so enterprises have from the 1st of December 2010 until the 1st June 2015 to change over to the CLP criteria, like with substances, if a mixture is already on the market on the 1st June 2015, the deadline is extended until 1st June 2017.

Enterprises can go ahead and apply the CLP rules for both substances and mixtures before these transitional dates.  If this is the case, it should be noted that only the CLP label can be used but both the existing CPL and new CLP classifications must be included in the Safety Data Sheet right up to the end of the transitional period. This is to allow enterprises to continue to use the existing CPL criteria right up to the end of the transitional period without losing the information.

A “GHS-converter” tool has been produced by BD Chemie to help you convert the classification of your substance from the existing CPL (DSD/DPD) criteria (Directive 67/548/EEC & Directive 1999/45/EC) to the new CLP criteria (CLP Regulation (EC) No 1272/2008).

This tool is particularly useful in the instance in which you import a mixture for which you need to notify the substances contained in it and for which only the classification according to existing CPL (DSD)  is available. In the case of substances, the GHS converter also checks whether there is an existing legal classification in former Annex I of the Dangerous Substances Directive 67/548/EEC (now: Annex VI of the CLP-Regulation). In the case of preparations, the translation table (Annex VII of the CLP Regulation) is used for reclassification. This is permitted in the transitional period (to 31 May 2015). The tool is freely available online.