LISA D. M. ALLEN
REACHReady Ltd, Kings Buildings, Smith Square, London SW1P 3JJ, United Kingdom.

Abstract

Now that hazardous substances are classified and labelled in accordance with CLP throughout the EU, attention turns to the supply of mixtures. From 1st June 2015, the CLP Regulation applies to all mixtures, from simple blends of a substance in a solvent through to complex, multi-stage formulations of mixtures within mixtures alike. Companies supplying formulated products should consider the most appropriate method to classify their mixtures; when compared to previous classification and labelling practices, suppliers of mixtures may have to rely on expert judgement more than simple calculations, and they may find that CLP requires significant label re-design and investment to achieve compliance.

INTRODUCTION

The EU Regulation on the Classification, Labelling and Packaging of substances and mixtures (CLP) (1) entered into force in January 2009. In the five years since, it has transformed the way in which the intrinsic properties of hazardous substances are identified and categorised, and how that information is communicated on packaging. Over the next three years the provisions of CLP will also be applied to mixtures. These changes bring such ‘classification’ and ‘labelling’ in the EU in line with the UN’s Globally Harmonised System (GHS) (2), which seeks to promote a high level of protection of both human health and the environment. This article aims to review the CLP Regulation and how it applies to substances and mixtures in the EU.

TRANSITION TO CLP
Through its transitional period from 2010 to 2017, CLP repeals the existing provisions on classification, packaging and labelling for supply, namely the Dangerous Substances Directive (DSD) (3) and the Dangerous Preparations Directive (DPD) (4). In doing so, the legislative framework shifts from national laws which implement these EU Directives, to a dire ...