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
9. Using the translation tables
Getting started
Hazard
classification
7. General features
of classification
8. Using harmonised
classifications
9. Using the
translation tables
10. Sources of
information
11. The role of
testing in CLP
12. Classifying
substances
13. Classifying
mixtures
Hazard
communication
Follow-up to
classification
REACH and EU
downstream
legislation
Translation of existing classifications
Annex VII to CLP provides a translation table for manufacturers, importers and
downstream users to translate existing DSD or DPD classifications to CLP
classifications. You may use these translation tables in case you or your supplier
have already classified a substance according to DSD before 1 December 2010 or
mixture according to DPD before 1 June 2015 and you have no further data available
for the substance or mixture and for the hazard class considered, see also the
guidance given in Part 1.8 of Module 2. In other words, the use of the translation table
allows you to assign CLP classifications to your substances or mixtures instead of
classifying them from scratch in accordance with CLP Title II and the criteria set out in
Annex I to CLP (CLP Article 61(5)).
The translation table covers those hazards where there is a reasonable correlation
between the DSD/DPD and CLP. Where there is no corresponding classification
under CLP, you will need to assess these properties yourself using the criteria in
Annex I to CLP. Insufficient correlation is given for example in the following situations:
• in the case of flammable solids, it is not possible to interpret across the DSD and
CLP criteria. Therefore, translation is not possible;
• in the case of acute toxicity, the classification bands of the two systems overlap,
and until data are available a minimum classification using the translation table
may be used. However, you should review this carefully in case you have data
which allows the substance or mixture to be classified more accurately.
Particular care needs to be taken when using the translation table for mixtures, as
there are a number of limitations to its use. For mixtures originally classified on the
basis of test results, the table may be used as for substances. However, for those
mixtures originally classified on the basis of the DPD concentration limits or the DPD
conventional calculation method, the proposed translation outcome under CLP should
carefully be considered, because of the differences in concentration limits and
calculation methods in CLP. In the particular case of “no classification” under DPD,
the table should not be used as there is no reasonable indication about a potential
translation outcome.
You can also use the translation table for substances with harmonised classifications
included in Table 3.1 of Annex VI to CLP where the entry for that substance does not
cover the hazard class or differentiation to be translated. You may check the Notes
column of Table 3.1 to see if this is the case (Note H).
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