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CLP - The relevant transitional period of mixtures comes to the end

On the 1st of June 2017 the grace period for mixtures on the market will expire.

The labelling and the packaging of the mixtures must meet with the relevant provisions of the 1272/2008 / EC, Article 62 and also has to be accompanied by a safety data sheet which contains the appropriate classification of the mixture.

 



The labelling and the packaging of the mixtures must meet with the relevant provisions of the 1272/2008 / EC, Article 62 and also has to be accompanied by a safety data sheet which contains the appropriate classification of the mixture.

The introduction of the CLP regulation can be regrded as the end of a long process. This also means (and will mean – see the end of this article) significant changes and tasks for companies of the chemical industries.  


Revision of safety data sheets (supervision)

Compilation of label draft

 

 

The impact of changes in legislation on the safety data sheets


Over the past 15 years, we experienced a dynamically changing regulatory environment on the field of chemical safety in the member states of the European Union. Thanks to those changes, the form and content requirements of safety data sheets had significantly changed both in respect of mixtures and materials.

Safety data sheets are always required to correspond to those regulations in force at the time which define the content and form of the data sheets. All of this- due to the specialized area that requires special knowledge - can not be called a simple task.

ToxInfo Kft. - as one of the leading chemical safety supplier of Europe - assists its partners to comply with relevant standards for more than 15 years and thereby had the possibility to experience the recent changes of legislation in the everyday practice. 

In our recent article, we consider the important changes of the past and observe the not too distant future in order to farewell from the well-known orange hazard symbols in a dignified manner.

 

Classification DSD/DPD


It is to be understood as the directive 67/548/EEC (DSD) on hazardous substances, and directive 1999/45/EC (DPD) on hazardous preparations.

The publication of DSD/DPD introduced the marking system that is used by all EU member states, moreover, several non EU states started using these guidelines in thefield of chemical safety.

R-phrases indicating risks, S-phrases indicating safe usage and black hazard symbols on orange surface appeared on the safety data sheets and on the labels.

Although in the recent years there were many changes in the above laws, we can still come across with the DPD marking system in the case of hazardous mixtures in safety data sheets (but only until the 1st of June 2017.).

 

The effect of REACH for the safety data sheets


The REACH (Registration, Evaluation, Authorization of Chemicals) regulation, which is the EU’s new regulation on chemical substances, brought a substantial change in chemical safety.

This is the only regulation declaring the chemical-tasks of manufacturers/importers, downstream users, distributors and authorities. The regulation entered into force on 1st of June 2007, after which the content and format requirements of safety data sheets were specified by the Annex II of the REACH regulation.  

At that time the introduction of GHS (Globally Harmonized System) in Europe was already under planning.

 

CLP - the appearance of GHS in the Community legal order


Then came the Regulation 1272/2008 / EC (CLP), which can be considered the introduction of the aforementioned European GHS.

CLP has integrated a completely new marking system into chemical safety, which brought radical changes in the field of the classificationa, labelling and packaging of substances and mixtures, resulting in new changes of safety data sheets, that tied the total transmission to strict deadlines.

Instead of the former hazard symbols, CLP uses pictograms - diamond-shaped graphic compositions with red borders. As opposed to the previous regulations, it applies hazard classes, which involves one or more hazard categories, moreover it involves two warnings – “Danger” and Warning”- to indicate the weight of the danger. The R and S sentences formerly used by DPD/DSD will be replaced by H and P sentences, and the EUH hazard statements, that are not part of GHS, will also be used.

 

The impact of Regulation 453/2010/EU


The data contained in the CLP Regulation was put into effect by  Regulation 453/2010/EU, modifying Annex II of the REACH regulation, creating another large-scale change concerning the content and the form of the safety data sheets.

After the 1st of December 2010 substances should be classified in accordance with the CLP regulation only, but for mixtures this deadline was 1st of June 2015. According to Annex I of Regulation 453/2010/EU before the deadline of 2015 mixtures were either classified according to the DPD regulations or had a dual classification, in which the CLP classification also appeared. So the period between the 1st of December 2010 and the 1st of June 2015 can be constituted as transitional period in the regulation of mixtures (this period can be extended until the 1st of June 2017, if certain conditions are met).

After the Annex II of Regulation 453/2010/EU came into force on the 1st of June 2015 the instructions of the CLP regulation became the standard, however, regarding mixtures we should not forget the other deadline, 1st of June 2017 either.

 

Our present and near future - The Commission Regulation (EU) 2015/830


The regulation in force is Regulation 2015/830/EC, which was introduced last year as an amendment of Regulation 453/2010/EU.  

In addition to transfer the Appendix I. and II. of the 45/2010/EU Regulation into a standardized from, this regulation has brought only a few changes in format and content compare to the previous laws.

 

DEADLINES


until the 1st of June 2017:


As for mixtures, there was a transition period between the 1st of December 2010 and the 1st of June 2015, after which the mixture has to be classified, labelled and packaged in accordance with the CLP regulation.  The transitional period is entirely up to 1st of June 2017. The reason for this is that in case of those products which were placed on the market before the 1st of June 2015 the classification, labelling and packaging according to DPD is still useable until the 1st of June 2017.

 

After 1 June 2017:


Important! After the 1st of June 2017 there will be no grace period, so product labels shall under no circumstances be made according to the DPD regulation, as well as safety data sheets shall not contain any classification according to the DPD regulation either.

It is recommended to prepare for the total transition, assess the stock, recall the products with DPD labels, or have the labels modified by partners on the spot before the above mentioned deadline.

It is important to note that the content of the label must be identical with the content of the safety data sheet. The first step of the changeover process is the compliance of the safety data sheet to the current laws.

 

The future...


Although DPD will disappear after almost 17 years, it will not mean that safety data sheets will change, or that the duties of chemical companies will decrease after the deadline.

The relevant regulations are constantly changing and despite the global harmonization efforts, in some of the member states- partly-stayed with the local regulations in chemical safety.

 

 

The MSDS Europe remains committed to support its partners in the whole process of transition.

For more information contact our customer service:

MSDS-Europe customer care

 

Tags:  1 June 201731 May 2017CLPDPDmixture


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