New Labelling of Chemicals

The regulation says "CLP" sets new rules for the classification, packaging and labeling of chemicals in Europe. The new system, implementing international recommendations of GHS (Globally Harmonized System or), and will gradually replace the existing European system. It applies mandatorily substances from 1 December 2010 and blends in June 2015.
CLP, the new European system
CLP is the name given to Regulation (EC) No 1272/2008 of 16 December 2008 relating to the classification, labeling and packaging of substances and mixtures, and amending and repealing Directives 67/548 / EEC and 1999/45/EC, amending Regulation (EC) No 1907/2006.

The acronym "PLC" in English means, "Classification, Labelling, Packaging" is to say "classification, labeling, packaging.

This text defines the new EU rules on classification, labeling and packaging of chemicals to the areas of labor and consumption.

This is the official text of reference in Europe that would implement the GHS in the EU in these sectors.
As a regulation, the CLP does not require transposition law into national law and directly applicable in the same way in all Member States. Published in the Official Journal of the European Union No. L 353 of 31 December 2008, it entered into force January 20, 2009
It is important not to confuse the GHS and CLP.
The GHS provides the basis for countries wishing to implement these recommendations. These countries are developing, in this case, legal texts such as the new EU regulation.
The implementation of the GHS may vary by country. It is therefore important to refer to specific texts elaborated by the country, not the GHS to know the rules of classification, labeling and packaging.

The CLP will gradually replace then fully repeal, in 2015 (unless otherwise), the existing European system flanked by two directives:
- Directive 67/548/EEC on classification, labeling and packaging of dangerous substances,
- Directive 1999/45/EC as amended, relating to the classification, labeling and packaging of dangerous preparations
To be applied in France, these directives are implemented as two arrested:
- Order of April 20, 1994 as amended (the transposition of the Directive as "substances")
- Order of November 9, 2004 as amended (the transposition of Directive
"Preparations").
Concrete changes related to CLP


CLP takes into account a large part of the recommendations of GHS.
Also, many differences are noted between the existing European system and this new text with regard to terminology, hazard identification, classification criteria and labeling. Among other changes, the CLP defines a new procedure, called a statement of the manufacturers and importers of certain substances

The term "substance" is retained but the "preparation" is replaced by "mixture".

The term "hazard category" is replaced by "hazard class".

A hazard class defines the nature of the danger, whether physical danger, a danger to health or environmental hazard.
Examples: flammable liquids, carcinogenicity, ... A hazard class may be divided into categories of risk.

The hazard categories allow a comparison of the degree of danger in this class.
Some definitions of CLP
Manufacturer: "any natural or legal person established within the Community who manufactures a substance within the Community"
Manufacturing "production or extraction of substances in a natural state"
Importer: "any natural or legal person established within the Community who is responsible for import"
Import "the physical introduction into the customs territory of the Community"

Downstream user: 'any natural or legal person established within the Community, other than the manufacturer or importer, who uses a substance, on its own or in a mixture, in the course of his industrial or professional activities. A distributor or a consumer is not a downstream user. A re-importer exempted pursuant to Article 2, paragraph 7, item c) of Regulation (EC) No. 1907/2006 (REACH) is considered a downstream user "
Distributor: "any natural or legal person established within the Community, including a retailer, who only the storage and marketing of a substance on its own or in a mixture, on behalf of third "
Marketing "from providing a product or make it available to a third party for consideration or not. Import shall be deemed to be placing on the market "
Producer of an article: "any natural or legal person who manufactures or assembles an article in the Community '
Article: "an object which, during the manufacturing process, shape, surface or design which determines its function than its chemical composition"
Provider: "Any manufacturer, importer, downstream user or distributor placing on the market a substance, on its own or in a mixture or a mixture"
New label, you are concerned
• You use chemicals in your workplace
In the coming months, you now see on your desktop chemicals with new labels: new hazard pictograms, new phrases ...
• In order to use chemicals safely, preserve your health and protect the environment, it is important to familiarize yourself with this new information.
You lead teams that use chemicals
The table below shows, in outline, your main obligations under the CLP.

Relationship between REACH and CLP

Regulation. REACH (Registration, Evaluation, Authorization and Restriction of Chemicals, that is to say, Registration, Evaluation and Authorisation of Chemicals) described the new European chemicals management. It aims to improve knowledge of the uses and dangers of these substances, to ensure effective control of risks associated with their uses and to restrict or prohibit their use.
It relies on four procedures: registration, evaluation, authorization and restriction.

CLP described, meanwhile, the new rules of classification, labeling and packaging of chemicals in Europe for the areas of labor and consumption.
CLP, replacing the system of classification and labeling of existing, will be a necessary tool for the implementation of Regulation REACH.qui identifies the dangers posed by chemicals to human health and the environment.
This is a crucial parameter in the REACH process, because many provisions of these regulations are based on the classification and labeling or refer.
Two examples:
and packaging of chemicals in Europe for the sectors of labor and consumption.

CLP, replacing the system of classification and labeling of existing, will be a necessary tool for the implementation of Regulation REACH.qui identifies the dangers posed by chemicals to human health and the environment.

This is a crucial parameter in the REACH process, because many provisions of these regulations are based on the classification and labeling or refer.
Two examples:
and packaging of chemicals in Europe for the sectors of labor and consumption.

CLP, replacing the system of classification and labeling of existing, will be a necessary tool for the implementation of Regulation REACH.qui identifies the dangers posed by chemicals to human health and the environment.

This is a crucial parameter in the REACH process, because many provisions of these regulations are based on the classification and labeling or refer.
Two examples:
- The registration dossier must include the classification and labeling of the substance and, in some cases, a chemical safety report based on this classification, which aims to assess risks and identify measures to reduce these risks.
- The licensing process: it aims to ensure control of risks arising from substances of greatest concern in providing for their gradual replacement. It is based on the classification of substances such as these involve substances classified as CMR 1 and 2 (according to existing system).
Regulatory tools available to update the labels and safety data sheets:

The CLP includes several "regulatory tools" useful for the classification of chemicals, namely:

- A list of harmonized classification and labeling of dangerous substances

- Conversion tables

- An inventory of classification and labeling.


Annex VI of the CLP is composed of the European list of hazardous substances for which a harmonized classification and labeling have been adopted at EU level. When you need to classify a substance included in this list, it is mandatory to apply the harmonized elements contained therein.
Part 3 of Annex VI is composed of two tables:

- Table 3.1: This is the list of harmonized classification and labeling of dangerous substances based on new rules of the CLP.

- Table 3.2: This is the list of harmonized classification and labeling
hazardous substances under the rules established system of classification and labeling of existing European (Directive 67/548/EEC). This table replaces the list in Annex I to Directive 67/548/EEC which has been suppressed for the entry into force of the CLP.
The list of dangerous substances listed in Part 3 of Annex VI is an evolving list.

This new regulation does not include all the tables 3.1 and 3.2 of Annex VI of the CLP. He mentions only the entries removed, altered or added to these tables.

Thus, when asked if a substance is classified and labeled harmonized, it is a first step, consult the Regulation (EC) No 790/2009 (1st ATP CLP ) and then CLP.
This 1st ATP CLP is mandatorily applicable from 1 December 2010.
Conversion tables to facilitate the conversion of classifications
Conversion tables are provided in Annex VII of the CLP to facilitate the direct transfer of a classification under the existing EU rules to meet the classification criteria of the new regulation. They can prevent firms from re-complete the classification process required as part of an initial classification (evaluation of relevant information on hazards through application of classification criteria).
These tables are useful for substances that have not been subject to classification and labeling is harmonized to say that are "autoclassées" by manufacturers.
The conditions for using these tables are listed in Annex VII.
The inventory of classification and labeling

This inventory, prepared and maintained by the European Chemicals Agency will be primarily powered by: -
information reported by manufacturers and importers of chemicals (see "You are a manufacturer, formulator, importer or distributor)
- Information presented as part of registrations under REACH
When they exist, the harmonized classification and labeling of the substance (excerpt from Annex VI of the CLP) will also be listed in this inventory.
Access to other information is regulated by the REACH
For substances "autoclassées" by the industry (and therefore no harmonized classification or labeling), it should refer to the classification proposed in the inventory. However, it will be possible for a manufacturer or importer of the substance classified differently so long to submit the reasons for the European Chemicals Agency.
Main differences between the GHS and CLP

The CLP does not incorporate all the recommendations of GHS. In addition, he retains certain provisions of the European System of Classification and Labelling of pre-existing, it also defines new European regulations in this area.

Moreover, unlike the GHS, the new regulation, which deals with areas of work and consumption, does not transport chemicals.
Furthermore, the GHS for the preparation of safety data sheets are now included in the REACH Regulation are not included in the CLP.

FIND IN OUR PUBLICATIONS IN OUR FILES "REACH", "DANGEROUS PREPARATIONS" AND ON-LINE ACCESS ON "DANGEROUS" ALL THE DETAILS ON THE NEW LABELING RULES AND REACH CLP.