CLP 2015: what obligations?

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What is CLP Regulation?

The acronym «CLP » means « Classification, Labelling, Packaging ». This Regulation came into force on 20 January 2009 and allows to implement the "Globally Harmonized system" (GHS) whitin the European Union in defining the new classification, labelling, and packaging rules for chemical products for the labor and consumption areas. This regulation replaces the DSD/DPD (Directives 67/548/CEE and 1999/45/CE).


pictogrammes clp 2015 guide obligations

The CLP regulation applies to most chemicals: only substances and mixtures, and established rules for the classification, labelling, and packaging for these products.

Concrectely, it redefines the hazard classification, introduces new labels and updates the Safety Data Sheets (MSDS), including new pictograms, precautionary statements,etc.

What are my obligations to CLP Regulation?

Whether you are a user, manufacturer or importer of chemicals, you are concerned with the new CLP (Classification, Labelling and Packaging) from the GHS Regulation (Globally Harmonized System) established by the UN.

clp 2015 guide obligations

The CLP Regulation requires several types of obligations (in chronological order), which are independent of

the annual tonnage substances or mixtures:

1. Classification


Who ?

Manufacturers, importers, downstream users including distributors

What does it means ?

Determine hazard classes of the substance or mixture according to the CLP regulation, knowing that this regulation redefines the hazard classification criteria compared to DSP / DPD system. This is a complex procedure that must go through the judgment of an expert. For the downstream users (including distributors) if they do not make changes in the formulation, they can keep the assigned classification by the manufacturer. This information is found in section 2 of the Safety Data Sheet.

2. Notification

notification-clp-2015-guide


Who?

Manufacturers and importers only

What does it means?

All hazardous substances and substances subject to REACH must be notified to ECHA via the C & L Inventory while the mixtures are exempt from listing.

3. Update of Safety Data Sheets


Who?

Manufacturers, importers, downstream users including distributors.

What does it means?

Update all SDS with the proper classification of formalism: they must contain the hazard information in CLP formalism only from 1 June 2015: the new hazard classes, new pictograms, new signal words and hazard , the associated safety advice, etc.

4. Labelling


pictogrammes-clp-2015-guide

Who ?

Manufacturers, importers, downstream users including distributors.

What does it means?

About the dangers related to the substance or chemical mixture via a labelling system defined by CLP formalism including new pictograms.

5. Packaging


Who ?

Manufacturers, importers, downstream users including distributors.

What does it means ?

Package substances and mixtures appropriately given their hazard classes. Packaging criteria are described here.

Summary of your obligations:

Good to know: All information related to the classification of substances and mixtures should be kept at least 10 years.

What is changing relative to the DSD/DPD formalism?

The CLP Regulation n°1272/2008, as well as changes the terminology pictograms.

comparaison pictogrammes clp 2015 dsd/dpd

In terms of terminology:

Now the term "preparation" is replaced by the term "mixture" and the term "hazard category" with "hazard class".

In terms of hazard class:

The 15 Hazard categories turn into 28 classes of hazards. Of the 28 classes of hazards, 16 of them are related to physical hazards, 10 of them are related to health hazards and 2 of them are related to environmental hazards.

For labelling:

The CLP Regulation sets up new icons to replace those of the old regulations DSD / DPD. Thus in addition to the classification symbol will be found, a warning and an indication of danger.

What are the new hazard classes?

Crédit : ministère de l'Écologie et du Développement Durable