Disagreement on proposed CLP transition periods

Published 
December 7, 2022

Revision of the CLP regulation

The revision of Regulation (EC) No. 1272/2008 on classification, labeling, and packaging of substances and mixtures (CLP) has been the subject of much debate for some time. The revision of the regulation is part of the EU Chemicals Strategy for Sustainability (CSS), but industry groups are opposing the European Commission's proposal for the revision. 

The proposed revision introduces new hazard classes into the CLP Regulation:

  • Endocrine disruption
  • Persistent, bioaccumulative and toxic (PBT) and very persistent, very bioaccumulative (vPvB) substances
  • Persistent, mobile and toxic (PMT) and very persistent, very mobile (vPvM)

You can download the free table prepared by EcoMundo summarizing the current hazard classes of the CLP regulation

The transition periods granted will be as follows:

  • 24 months for new substances
  • 36 months for mixtures
  • 42 months for substances on the market (before the date of entry into force)
  • 60 months for mixtures already on the market

The European Commission's final proposal will be published before the end of the year, but no fixed date has been given as of yet.

Impact of transition periods for the industry

The proposed transition periods would allow 12 months for formulators to comply with the new requirements. However, formulators say they are running out of time to comply with the transition period, which is provided in the European Commission's proposal.

If this proposal is validated, downstream users will be required to re-label or reformulate their mixtures and products. Considering the waiting time to receive the SDS (Safety Data Sheet) and labels with an updated classification, FIPEC (French Industrial Group Representing the Paint, Ink, Adhesive and Wood Preservation Industries) says that this time frame would not be sufficient.

Why is the revision of the CLP regulation necessary?

The regulation ensures a high level of protection for human health and the environment within the EU, while ensuring the free movement of substances and mixtures. This protection is established by the setting up of hazard classes allowing the assignment of classification criteria to substances by category of danger.

The European Commission has launched a Green Deal Action Plan as part of its Chemicals Strategy for Sustainability (CSS) to support a transition to safer and more sustainable chemicals. This action plan would improve communications on the hazards and toxicity data of chemical substances and promote a more appropriate classification of these substances. An additional objective is to remove harmful chemicals from the market (except for substances deemed essential for health, safety and society and substances for which substitution is not possible).

Within this framework, all regulations are subject to revision (REACH, CLP, cosmetics, etc.), bringing restrictions or new obligations for industries to follow. 

The revision of these regulations refers to analyses of environmental, economic, and social consequences, all while taking into account the impacted stakeholders.

Thus, the addition of new hazard classes to the CLP Regulation would allow safer classifications and better knowledge of the substances and mixtures placed on the market.

How to anticipate the revision of the CLP regulation

EcoMundo offers you an audit of your portfolio of chemical substances in order to determine the impact that these changes will have on your substances and then establish an action plan to anticipate all these new developments.

We also offer expert software solutions to support you throughout the regulatory process: 

  • MAT Factory ensures an expert and automated regulatory watch that is specific to all your products
  • SDS Factory allows you to generate compliant SDSs in less than 5 minutes in accordance with the most up to date CLP requirements

Want to know more about the CLP regulation?

For more information, please contact one of our team members below: Contact us!

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