CLP

Overview of CLP

CLP (Regulation (EC) 1272/2008) is the acronym for Classification, Labelling and Packaging of substances and mixtures. This Regulation entered into force on the 20th of January 2009 and is based on the Globally Harmonized System (GHS), a set of recommendations drafted by the United Nations.

The purpose of the CLP regulation is to clearly communicate chemical hazards to workers and consumers across the European Union by classifying and labelling chemicals appropriately.

The primary goal of CLP is to protect human health and the environment. All parties involved in the supply chain are responsible for complying with the classification, labelling and packaging rules. Before chemical products enter the market, manufacturers and suppliers must assess the potential risks these substances and mixtures pose to people and the environment and classify them based on their identified hazards. Hazardous chemicals must be labelled using a standardised system to ensure that workers and consumers understand the risks before use.

Moreover, CLP is closely connected with:
•    REACH, especially in relation to safety data sheets;
•    various other European regulations, including those on Biocides, Plant Protection Products, major industrial accident prevention (Seveso Directive) and workplace chemical safety (Carcinogens and Mutagens Directive, Chemicals Agents Directive).

CLP requirements apply to chemical substances (such as chloric acid, ethanol, iron, cooking salt, ammonia, bleach...) as well as to mixtures (detergents, paints, lacquers, concrete, oil...). Unlike the REACH Regulation, CLP does not provide any exemptions. Therefore, all hazardous chemicals falling under the scope of CLP must be notified and included in the Classification and Labelling (C&L) inventory.

In this section we will mainly focus on the C&L inventory. Visit ECHA’s webpage for further information and guidance on the CLP regulation.

Classification and labelling (C&L) inventory

The Classification and Labelling (C&L) inventory is a database maintained by ECHA that contains information on the classification and labelling of substances placed on the European market. It includes data on both notified and registered substances, as well as the list of harmonised classifications and labelling specified in Annex VI of the CLP Regulation.

Within the framework of the C&L inventory, manufacturers and importers are required to notify the classification of all substances placed on the market.

A notification to ECHA must be submitted when:
•    substances are manufactured and/or imported and are subject to registration under the REACH Regulation;
•    substances are classified as hazardous;
•    mixtures contain a hazardous substance present above the relevant concentration limit, causing the mixture itself to be classified as hazardous;
•    articles contain a substance that is subject to registration according to Article 7 of the REACH Regulation.

The notification must be made within one month of placing the substance on the market. For importers, this one-month period begins from the date the substance, either on its own or within a mixture, is physically brought into the territory of the European Union.

Note:
•    There are no exemptions from C&L notification requirements. Therefore, even substances exempt under the REACH Regulation must be notified.
•    If a manufacturer or importer has already submitted a registration dossier under REACH for a substance, a separate C&L notification is not required since the necessary classification and labelling information is already included in the registration dossier.

C&L notifications must be submitted electronically through the REACH-IT portal on the ECHA website. There are three submission methods available:
•    Directly online using REACH-IT;
•    Creating an IUCLID dossier and submitting the notification via REACH-IT;
•    Uploading a bulk notification as an XML file through REACH-IT.

More information and guidance concerning C&L notifications can be found on ECHA’s website.