Regulation (EC) No 1272/2008 of the European Parliament and of the Council of 16 December 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 entered into force on 20 January 2009 in all EU Member States. It is known by the acronym “CLP”.
The CLP Regulation is based on the Globally Harmonised System on the classification and labelling of chemicals (GHS).
CLP is legally binding in all EU Member States and directly applicable in all industrial sectors. It requires all manufacturers, importers and downstream users of substances and mixtures to classify them according to harmonised rules, label and package them in accordance with their hazardous properties before they are placed on the market.
Consolidated version of the CLP Regulation
The consolidated version of Regulation (EC) No. 1272/2008 (CLP Regulation) incorporates all amendments and corrections to the CLP Regulation up to the date indicated in the header of the first page of the Regulation. The consolidated version of the CLP Regulation does not contain commentaries. These can be found in the original text of the CLP Regulation. The text published in the Official Journal of the European Union is legally binding.
https://eur-lex.europa.eu/legal-content/SK/TXT/PDF/?uri=CELEX:02008R1272-20190726&from=sk
The harmonised classification and labelling for certain hazardous substances is set out in Tables 3.1 and 3.2 of Annex VI and also in the so-called “C&L Inventory” on the website of the European Chemicals Agency.
https://echa.europa.eu/information-on-chemicals/cl-inventory-database
Poison centres
The European Commission has adopted a “delegated act” supplementing the CLP Regulation by postponing the deadline for the first reporting of harmonised information to poison centres from 1.1.2020 to 1.1.2021 for mixtures intended for consumer use.
https://ec.europa.eu/transparency/regdoc/rep/3/2019/SK/C-2019-7611-F1-SK-MAIN-PART-1.PDF
The requirements for harmonised information on hazardous mixtures are different from the notifications currently required by national authorities of the EU Member States. It is therefore necessary to start addressing the new obligations systematically – to make an inventory of the required and available data, to identify the missing information and how to obtain it in a way that complies with the requirements of Annex VIII to the CLP Regulation.
Regardless of where a company is located in the supply chain, the obligation to report data is determined by the end use of the mixture. The supplier at the beginning of the supply chain should provide information as soon as possible to downstream users who are close to consumer uses, so that they can make the relevant notifications correctly and in a timely manner.
An online portal for submitting information has been made available on the ECHA website (ECHA Submission portal). Companies can use this tool for the notification of their products. However, companies are not obliged to use this system exclusively.
CHEMDOX software provides comprehensive IT solutions for UFI and notification information and thus provides very convenient solutions for its users.
ECHA recommends 5 steps for fulfilling notification obligations:
- Start with preparation and find out which Member States accept harmonised notification and which will require individual submissions, or a combination of both;
- Perform a status analysis and identify missing information;
- Act actively, if necessary, to create working groups, communicate, monitor current developments;
- Invest in communication in the supply chain;
- Determine which tool is most suitable for the preparation and execution of notifications.
UFI Codes
The UFI code is a unique identifier, a 16-character alphanumeric code that will be mandatory on the label of products containing a hazardous mixture.
In addition to the UFI, further information on the hazardous mixture and related products is required to be provided to national institutions such as the National Toxicology Information Centre (NTIC) in Slovakia.
Such information includes composition, trade name, colour, packaging, product category and toxicological information.
The aim of the UFI is to create a clear link between the information provided with the product placed on the market.
The condition for assigning a UFI is that all products that are labelled and notified with the same UFI must have the same composition of the hazardous mixture.
From 2021, a new labelling element will be included on product labels and tags – a 16-character code called the Unique Formula Identifier (UFI).
The so-called transition period for products already placed on the market and notified to the competent authorities of the Member States before 1.1.2021 is set until 1 January 2025. From 2025, the UFI will be mandatory on the labels of all products classified for health or physical risks.
Importers and downstream users who place such products on the market will have to provide specific product information, including the UFI, to the designated national authorities where they list the products.
Changes to the CLP Regulation 2024-2027 and new obligationsSDS – New requirements 2023Compliance DeadlinesGeneral Requirements for Refill Stations New Hazard Classes in the Updated CLP Regulation Classification Approach for Complex Substances
General Obligations of Distributors Mandatory Hazard Information in Advertisements Acute Toxicity Estimates (ATE)Distance Sales Requirements Under the CLP Regulation Supplier Establishment Requirements Under the CLP Regulation
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