Introductory Guidance on the CLP Regulation - ECHA - Europa

Basic guidance to Regulation (EC) No 1272/2008 on Classification, Labelling and Packaging of substances and mixtures
you, for example in Safety Data Sheets that accompany substances and mixtures
(CLP Article 4 (5)).
The deadlines for any changes to be made are set out in section 4 of this guidance
document.
To gain an understanding of the scale of the work involved, you must be prepared to:
• apply the CLP criteria to your substances and mixtures 2 , or use their existing
classifications and the Annex VII translation tables if you have no data on your
substances or mixtures. In this situation you should take note of the guidance on
the use of these tables which is available in Part 1.8 of Module 2. You should not
forget to consider any substances or mixtures that are currently not dangerous
under DSD and DPD as under CLP some previously non-dangerous substances
or mixtures may be classified as hazardous;
• consider the REACH registration deadlines for your substances and the likely
amount of information that may be available to you on these substances. You
may need to contact your suppliers for more information; and
• contact your suppliers to see how they anticipate CLP and how it will affect the
substances or mixtures you use. If you formulate new mixtures using other
mixtures as an ingredient (mixtures within mixtures), you will need to contact your
suppliers to discuss what information on the mixture and its components will be
available to you, including through Safety Data Sheets. Likewise, if you supply
mixtures to customers who formulate them into other mixtures, you will need to
consider how you will share information on the mixture and its components with
them.
You should think about the resources that you might need, asking yourself:
• do I have sufficient appropriate technical and regulatory staff, or will I need
additional resources or external expertise
• Safety Data Sheet authoring software – do I need to update my system
• how will I generate new labels and
• packaging – will any of my packaging that I applied in accordance with DSD, DPD
or transport legislation need to be changed due to transition to CLP
2
As a producer or importer of an article you are only affected by CLP if you produce or
import an explosive article as described in section 2.1 of Annex I to CLP or where REACH
Article 7 or 9 provide for registration or notification of a substance contained in an article.
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