ECHA updates two guidance documents on classification and labelling
The 8th ATP to CLP was published on 14 June 2016 in the Official Journal of the European Union, under the official title Commission Regulation (EU) 2016/918 of 19 May 2016 amending, for the purposes of its adaptation to technical and scientific progress, Regulation (EC) No 1272/2008 of the European Parliament and of the Council on classification, labelling and packaging of substances and mixtures.
The compliance deadline for manufacturers and importers to update safety data sheets and labels to conform to the new rules for substances and mixtures is:
1 February 2018
Distributors have an additional 2 years, until 1 February 2020, to relabel products already on the market at that initial deadline.
In order to keep the guidance documents in alignment with these amendments to the CLP, ECHA published updates to two guidance manuals on 4 July, 2017:
- Guidance on the Application of the CLP Criteria - v5.0
- Guidance on labelling and packaging in accordance with Regulation (EC) No 1272/2008 - v3.0
The first document, on application of the CLP criteria, mostly updates references to the regulation, eliminates references to the now fully repealed Dangerous Substances Directive, and updates some test methods and decision logic. There are no new hazard classes or categories established in the 8th ATP of CLP (or 5th revision of GHS), so nothing really big is introduced in this guidance. Updates to a lot of P-statements are reflected correctly now in the guidance to minimize confusion.
The second guidance, on labelling and packaging, will be more useful, as it redefines the recommendations on how to reduce the collection of P-statements to comply with Article 28 of the CLP which states:
Article 28 Principles of precedence for precautionary statements
1. Where the selection of the precautionary statements results in certain precautionary statements being clearly redundant or unnecessary given the specific substance, mixture or packaging, such statements shall be omitted from the label.
2. Where the substance or mixture is supplied to the general public, one precautionary statement addressing the disposal of that substance or mixture as well as the disposal of packaging shall appear on the label, unless not required under Article 22. In all other cases, a precautionary statement addressing disposal shall not be required, where it is clear that the disposal of the substance or mixture or the packaging does not present a hazard to human health or the environment.
Not more than six precautionary statements shall appear on the label, unless necessary to reflect the nature and the severity of the hazards.
Now that the guidance is finalized, it's full speed ahead towards the 1 February deadline next year.