If your company offers chemical products for sale on the internet, it's time to check your compliance status. A pilot enforcement project initated by the European Chemicals Agency checked 1314 internet advertisements, finding 1083 (82%) out of compliance with the requirements of the Classification, Labelling and Packaging (CLP) Regulation. Due to the high rate of non-compliance found, further inspections can be anticipated. 

The types of products inspected covered: 

• Household products (e.g. cleaners, pool treatments, plumbing maintenance - 37.7%)
• Construction materials (e.g. paints, solvents, adhesives - 16.7%)
• Automotive maintenance (e.g. cleaners, coatings, lubricants - 14%)
• Hobby items (e.g. glues, paints, solvents - 11.9%)
• Garden goods (e.g. plant protection products, biocides - 9.3%)
• Other (10.4%)

Almost all of the inspections evaluated professional sellers' on-line shops rather than auction sites or other platforms. Four of the inspections resulted in referral to public prosecutors for criminal charges. 280 fines were issued. In other cases, an administrative order, a written order, or a formal verbal order has been issued. Follow-up activities were not completed at the time of reporting for a large number of cases as well. 

As this was only a pilot project, companies can expect that enforcement investigations will continue. In the official recommendations of the pilot project report, ECHA encourages the national enforcement authorities to continue to perform inspections of on-line advertisements or to initiate such enforcement in the case of member states that did not participate in the pilot project. Due to the extremely high rate of non-compliance found, the report also recommends that on-line sales should be targeted by another official REACH/CLP Enforcement Forum project.

A link from the sales description to a safety data sheet does not fulfill the supplier's obligations under the Regulation on Classification, Labelling and Packaging (CLP). If you are not sure what your obligations are, let Chemical Safety Consutling help you.