Introduction
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 replaced the two previously existing laws or legal instruments, the Dangerous Substance Directive (DSD) and the Dangerous Preparation Directive (DPD).
CLP is based on the Globally Harmonized System (GHS), a set of recommendations drafted by the United Nations. The CLP Regulation is applied to substances since 2010 and to mixtures since June 2015.
Remark: For mixtures already classified, labelled and packaged according to DPD and placed on the market before the 1st of June 2015 a transitional period existed and companies had to re-label and re-package their mixtures at the latest by the 1st of June 2017.
Aim
The aim of CLP is to ensure that hazards related to chemicals are clearly communicated to workers and consumers in the European Union through the classification and labelling of chemicals.
The main objective behind CLP is to preserve human health and the environment, and it is the duty of all actors in a supply chain to ensure compliance with classification, labelling and packaging requirements. Thus, before placing chemical products on the market, the industry must determine the potential risks of these substances and mixtures to human health and the environment, and classify them in accordance with the identified hazards. Hazardous chemicals must also be labelled according to a standardised system, so that workers and consumers are aware of their effects before using them.
In addition, CLP is strongly linked to:
- REACH, in particular with regard to safety data sheets;
- A number of other European laws, such as those concerning Biocides, Plant Protection Products, major industrial accidents (Seveso), and the legislation on chemicals at the workplace (Carcinogens and Mutagens Directive, Chemicals Agents Directive).
For more information on classification and labelling please see the respective pages.
Scope
CLP requirements apply to chemical substances (such as chloric acid, ethanol, iron, cooking salt, ammonia, bleach...), mixtures (detergents, paints, lacquers, concrete, oil...) and explosives (section 2.1, Annex I CLP).
However, the CLP Regulation shall not apply to the following:
- Radioactive substances and mixtures (Council Directive 96/29/Euratom);
- Substances and mixtures which are subject to customs supervision;
- Non-isolated intermediates;
- Substances and mixtures for scientific research and development;
- Waste (Directive 2006/12/EC).
CLP shall not apply to substances and mixtures in the following forms, which are in the finished state, intended for the final user:
- Medicinal products (Directive 2001/83/EC);
- Veterinary medicinal products (Directive 2001/82/EC);
- Cosmetic products (Directive 76/768/EEC);
- Medical devices (Directives 90/385/EEC, 93/42/EEC and 98/79/EC);
- Food or feeding stuffs as defined in Regulation (EC) No 178/2002 including when they are used as a food additive in foodstuffs (Directive 89/107/EEC), as a flavouring in foodstuffs (Directive 88/388/EEC and Decision 1999/217/EC), as an additive in feeding stuffs (Regulation (EC) No 1831/2003), in animal nutrition (Directive 82/471/EEC).
Remark: There are no exemptions under the CLP Regulation in contrast to the REACH Regulation (tonnage dependent registration obligation > 1t/y, Annex V, polymers). Thus, any hazardous chemical is in the scope of CLP and has to be notified in the C&L inventory.