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
be transferred from Annex I to DSD to Annex VI to CLP, e.g. in cases of a minimum
classification under CLP. Again the classifications for acute toxicity and STOT,
repeated exposure, may be particularly affected.
If you are using the substance in a mixture, you should take account of any SCLs
and/or M-factors assigned to the entry for that substance when classifying your
mixture. Where an M-factor is not given in Part 3 of Annex VI for substances
classified as hazardous to the aquatic environment, acute category 1 or chronic
category 1, you shall set an M-factor. When a mixture including the substance is
classified using the summation method, this M factor shall be used.
Unlike Annex I to DSD, Table 3.2 of Annex VI to CLP no longer includes the generic
concentration limits. These have been removed to improve readability and improve
consistency with the 2 nd ATP of Directive 1999/45/EC (DPD). Table 3.2 is applicable
with the entry into force of CLP.
You should also make sure you fully consider the impact of any special instructions
which appear in the Notes column of Table 3.1 of Annex VI to CLP. These Notes may
adjust the final classification because:
• the substance (acids, bases, etc.) is placed on the market as an aqueous solution
at various concentrations;
• the route of exposure or the nature of the effects leads to a differentiation of the
classification of the hazard class;
• the substance is marketed in a form which does not have the physical hazards
indicated by the classification;
• the substance has a stabiliser or inhibitor which may affect the classification;
• for certain complex oil- and coal-derived substances, the substance contains less
than the indicated level of a particular marker substance; or
• the substance has only been classified for some hazard properties.
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