Implementing a new, complex system

The Classification, Labelling & Packaging (CLP) Regulation is the EU commitment to implement the United Nations Globally Harmonised System of Classification and Labelling of Chemicals (GHS.) Implementation of the CLP Regulation is a step towards a worldwide, standardised system for classification and labelling of substances and preparations. 

On 1 December  2010, all chemical substances were due to be classified and labelled according the new system. Compliance for mixtures is due by June 2015.

An inventory of classification is part of the CLP regulation and requires a notification for all substances that will have to be registered under REACH and for all the rest that don’t have to be registered but are classified as hazardous.

The CLP Regulation also looks at the harmonised classification and labelling of substances, essentially for carcinogenic, mutagenic and substances toxic for reproduction and for respiratory sensitisers. Member States will, in the vast majority of cases, prepare the dossier that will be discussed in the Risk Assessment Committee at the European Chemicals Agency.

Cefic’s position on CLP and GHS

Cefic believes that the CLP Regulation and GHS can play a useful role in supporting public trust in the safe use of chemical products in Europe and worldwide. 

Cefic’s contribution to CLP and GHS

Cefic is supporting its member companies in the practicalities of complying with the CLP Regulation, with a particular emphasis on helping small and medium-sized enterprises. Cefic is preparing training packages to help smaller companies cope with the new regulation.

Next Steps

As of June 2015, mixtures must be classified and labelled under the new system. This will involve many more companies than those making substances: manufacturers of paints, adhesives, detergents, lubricants and many other mixed chemical products will be subject to the new rules. Classifying a mixture correctly is also likely to prove more complex.

Cefic believes this will be a major difficulty for many SMEs, who will have much more trouble doing it correctly than now.
GHS is intended to be a dynamic process, with updates every two years to the so-called Purple Book.   Any update of the CLP Regulation should be initiated by European legislators at the UN level.
Therefore, updates of the European CLP Directive will be initiated by the UN Subcommittee of Experts. Cefic is actively involved in such discussions at the UN level.