CLP or CLP Regulation is the new European Regulation on Classification, Labelling and Packaging of chemical substances and mixtures. The legislation introduces throughout the EU a new system for classifying and labelling chemicals, based on the United Nations’ Globally Harmonised System (UN GHS).
CLP is about the hazards of chemical substances and mixtures and how to inform others about them. It is the task of industry to establish what are the hazards of substances and mixtures before these are placed on the market, and to classify them in line with the identified hazards. In case a substance or a mixture is hazardous, it has to be labelled so that workers and consumers know about its effects before they handle it. Note that “mixture” means the same as the term “preparation” which has been used so far.
There are certain timelines for industry to classify and label their substances and mixtures in line with the CLP rules. Also, industry must notify hazardous substances and mixtures to a central inventory.
The notification of substances placed on the market on 1 December 2010 is due on 3 January 2011. The tools for notification are available. You can submit your notification now. The substances must be notified within one month from being placed on the market.
Who has to submit a notification?
If you have not registered by December 1st 2010 (first phase-in deadline): you have to notify a substance to the Classification & Labelling (C&L) Inventory established at ECHA in cases where you are placing the substance on the market and you either:
- Manufacture or import the substance and it is subject to registration under the REACH Regulation; or
- Manufacture or import the substance and it is classified as hazardous, irrespective of the quantity; or
- Import a mixture which contains the substance that is classified as hazardous and is present above the relevant concentration limit, which results in the classification of the mixture as hazardous according to the CLP Regulation; or
- Import an article containing substances which are subject to registration under Article 7 of the REACH Regulation.
As a first step, you should read the Practical guide 7: How to Notify Substances to the Classification & Labelling Inventory (see below) which helps you to identify whether you are obliged to notify your substance to the C&L Inventory. The guide will also provide you with an introduction on how to do the notification in practice.