Understanding EU Classification, Labelling and Packaging (CLP) Regulation Deadline

Manufacturers, importers or formulators must comply with EU Regulation (Regulation (EC) No 1272/2008)

08 November 2016

The European Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures came into force on 20 January 2009 in the whole of EU. It is commonly abbreviated to "CLP Regulation" or "CLP". The CLP regulation sets our criteria for the classification, labelling and packaging of hazardous chemical products placed on the EU market for industrial, professional and consumer use. This includes even those chemical products supplied in very small quantities. However, a few chemical product types are exempt from CLP obligations - for example, finished cosmetics, veterinary and medicinal products.

CLP has had a phased transitional period of the classification and labelling rules and is gradually replacing the previous rules implemented by the Dangerous Preparations Directive (DPD) and Dangerous Substances Directive (DSD). As we migrate from the DSD/DPD systems manufacturers and distributors supplying hazardous chemical products into the EU need to be aware of the cut-off dates for classification and labelling and ensure that those products are updated accordingly. For substances, the deadline for classification, labelling, and packaging according to the CLP rules was 1 December 2010 with a further 2 year window to update any substance classified to DSD which was already in the marketplace. As such, any substance already placed on the market must now be labelled in full accordance to the new CLP classification system.

Any mixture already placed on the market before the cut off of 1 June 2015 and already classified to DPD may postpone its re-labelling and repackaging according to the CLP rules until 1 June 2017. We are now approaching the final deadline in the grace period for chemical mixtures, and suppliers of chemical mixtures still classified to DPD should start thinking about re-labelling their chemical products if they are planning to supply these past the 1st June 2017 deadline.

If you manufacture, import or formulate and supply mixtures you must classify and, where required, label them to CLP before placing them on the market. Are you about to place on the market a new batch of an existing product? Or perhaps you have a new formulation to supply? If so, you need to ensure that your chemical product is classified according to CLP and that your labels are CLP compliant. Some examples of product affected could include detergents and household cleaners, candles, air fresheners, household chemical products such as adhesives and paints, DIY products, and vehicle care and maintenance products.

Safety data sheets for chemical products supplied in the EU should ideally be up to date with the latest amendments to the REACH format of safety data sheet included and suppliers should begin to classify their products to CLP.

So, if you think this will impact the products that you are supplying, now is the time to bring in the chemical and regulatory experts at Intertek to help.

Today's expert blogger is Dr. Chris Brennan, one of Intertek's global experts in cosmetic safety and regulatory affairs. Dr. Brennan has extensive experience in providing regulatory support to the global cosmetics and personal care industry. His background is originally organic chemistry specializing in drug design and hit-to-lead, medicinal, combinatorial and analytical chemistry within the pharmaceutical industry. He is currently Manager of the Intertek Toxicology group based at Leicester, England.