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CLP and REACH - Current Status

The United Nations GHS is implemented in the European Union through the CLP Regulation. The abbreviation "CLP" stands for Classification, Labelling and Packaging. CLP is complemented by the REACH regulation, which regulates the registration, evaluation, authorization and restriction of chemical substances as well as the communication in the supply chain. Both directives in turn are optimized by regular updates. As for CLP, it is the so called "ATP" ("Adaptation to Technical Progress"). REACH applies at the level of Regulation 2015/830, which concerns changes to the annex of the Safety Data Sheets.

REACH Registration and its Challenges

With the coming in to force of REACH and itsgradual implementation manufacturers and importers of substances or mixtures constantly face new obligations. Thus, companies producing or importing one tonne chemicals or more per year in the European Economic Area are obliged to register them with the European Chemicals Agency (ECHA). The registration under REACH is carried out by transmitting all substance information in the form of a dossier, which, however, requires appropriate expertise from the companies. Without prior registration, the motto is "no data, no market". In this case, both the manufacture and the market introduction of the chemical in question are prohibited.

11. ATP of CLP

The CLP Regulation currently applies to the 11th ATP. The European Commission published the Regulation 2018/669 on 16 April, 2018. It has been mandatory since 1 December, 2019, whereby suppliers were allowed to act in accordance with the changed version before this date. In terms of content, the eleventh update mainly concerns changed language regulations in Table 3 "List of harmonized classification and labeling of dangerous substances" in Part 3, Annex VI to CLP Regulation. It contains international adaptations and translations of chemical substance names with harmonized classifications in all official EU languages. New or changed substance classifications, however, are not provided.

CLP and the Future Transitional Periods

As to CLP, there are a number of future transitional periods which must be considered immediately on the given date. These include:

  • 1.5.2020: CLP: The 13th ATP (EC Regulation 2018/1480) becomes mandatory for substances and mixtures.
  • 17.10.2020: CLP: The 12th ATP will adapt CLP to GHS Revision 7 (currently GHS Revision 5).
  • The 14th ATP has not yet been released. It will contain new and changed classifications in Annex VI, as well as new EUH phrases.

Legally binding interpretations of REACH and CLP are handled by the national help desks. For further information, please contact Qualisys.