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
• a downstream user (including a formulator of mixtures or a re-importer of
substances or mixtures) may take over the classification for a substance or
mixture derived in accordance with Title II of CLP by an actor in the supply chain,
for example from a Safety Data Sheet; provided that he does not change the
composition of the substance or mixture (CLP Article 4(6)). Also, a downstream
user must ensure that any (re-)labelling and (re-)packaging of a substance or
mixture should be in accordance with CLP Titles III and IV (CLP Article 4(4)).
The classifications of all substances notified or registered under REACH or
CLP will be included in a classification and labelling inventory established
at the Agency (CLP Article 42). The inventory will indicate whether a
classification is harmonised or whether it has been agreed between two or
more notifiers or registrants
Producers of articles must provide information on substances contained
in articles to the Agency as far as these are substances of very high
concern (SVHC), they are present in those articles above 1 tonne per
producer or importer per year and contained in the articles in
concentrations above 0.1% (w/w) (REACH Article 7(2)). The information to
be provided also includes the use(s) of the substance(s) in the articles and
the use(s) of the articles (REACH Article 7(4))
Self-classification and harmonised classification
CLP includes provisions for two sorts of classification: self-classification and
harmonised classification. If you are not familiar with these terms, ‘harmonised
classification’ and ‘self-classification’ are described briefly below:
• Self-classification: the decision on a particular hazard classification and
labelling of a substance or mixture is taken by the manufacturer, importer or
downstream user of that substance or mixture, or, where applicable, by those
producers of articles who have the obligation to classify, see Table 2.5 of section 2
of this document.
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