Distributors must ensure that substances and mixtures are correctly labeled and packaged before being placed on the market. The key responsibilities include:
Maintaining Label Integrity:
- Ensure that the product bears the original label from the supplier, or if relabeling is required, it must fully comply with CLP requirements.
- Labels must be legible, firmly attached, and in the correct language(s) for the target market.
- Notification and Data Submission:
- Distributors placing hazardous mixtures on the market in other Member States or rebranding/relabeling them must submit information for emergency health response to appointed bodies.
- This obligation does not apply if the required data has already been provided by upstream suppliers.
Compliance Deadlines:
- Mixtures for consumer/professional use: Compliance required since January 1, 2021.
- Mixtures for industrial use: Compliance required from January 1, 2024.
- All SDS must comply with updated formatting rules by 31 December, 2022.
- Mixtures notified before compliance dates: Must be updated by January 1, 2025 if relevant changes occur.
- If new hazard information becomes available, distributors must update labels within 18 months from the date of the classification change.
2. Packaging and Safety Measures
Distributors must ensure compliance with packaging and safety requirements, including:
- Child-resistant fastenings and tactile warnings for hazardous mixtures.
- Tamper-proof seals if required for specific classifications.
- Use of standard formula compositions for fuels and certain mixtures as per Annex VIII.
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