The CLP Regulation came into force on 20 January 2010 and although it has not attracted as much attention as REACH did, in many ways it is just as important for companies.
One key difference from REACH is the very obvious international coverage. CLP implements in the EU the Globally Harmonized System for the classification and labelling of chemicals (GHS). The GHS will continue to be implemented in most countries across the world over the coming months and years. Time and effort spent implementing CLP in the EU should therefore provide benefits to companies in improving their access to non-EU markets. It is therefore important for such companies to plan their implementation activities with a global view rather than focusing just on the EU.
The three most pressing deadlines under CLP are:
- 1 December 2010 - for the (re)classification of substances in accordance with CLP;
- 3 January 2011 - notification to the classification and labelling inventory of substances placed on the market on 1 December 2010 (notifications are due 30 days after placing on the market starting from 1 December 2010); and
- 1 June 2015 - for the (re)classification of mixtures in accordance with CLP.
There are transitional arrangements for the (re)classification of substances and mixtures already placed on the market.
CLP also requires the development of a classification and labelling inventory by requiring those placing substances on the market (on their own and in mixtures) to notify specific information to the European Chemicals Agency. It should be noted that there is no tonnage threshold for these notification requirements, in contrast to the registrations under REACH.
The notification requirement applies 30 days after a substance is placed on the market starting from 1 December 2010. The deadline for many will therefore be 3 January 2011.