GHS (CLP/GHS system) IN PRACTICE - Agencija za hemikalije

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Food, additives and aromas as well as feedstuff and additive for feedstuffSubstances and mixtures which are in the finished state and intended for the final user as food, additives andaromas as well as feedstuff and additive for feedstuff are on the whole exempted from the provisions of theCLP/GHS Regulation.1.6 Will plant protection or biocidal products have to be classified and labelled in accordance with CLP/GHS system?Active substancesActive substances contained in plant protection or biocidal products will have to be classified and labelled inaccording to the CLP/GHS Rulebook as of 1 October 2011. In contrast to other substances supplied and used inthe industrial supply chain, all hazard classifications of these substances will normally be harmonised. Labells shallinclude any supplemental information required by Law on Plant Protection Products (“Official Gazette of RS” No41/09) or Law on Biocidal Products (“Official Gazette of RS” No 36/09)From 1 October 2011 active substances within the scope of Regulations on plant protectionor biocidal products, if placed on the Serbian market ON THEIR OWN, have to be clasifiedand labelled in accordance with CLP/GHS Rulebook!MixturesA mixture containing one or more active substance in a biocidal or plant protection product, will have to beclassified and labelled in accordance with CLP/GHS Rulebook in line with the transitional provisions. Labelsshall include any supplemental information required by Law on Plant Protection Products (“Official Gazette of RS”No 41/09) or Law on Biocidal Products (“Official Gazette of RS” No 36/09) as appropriate. Such information wouldhave to be placed in the section for supplemental information on the label.Plant protection or biocidal products will have to be be clasified and labelled inaccordance with CLP/GHS Rulebook in line with the transitional provisions!Labells shall also contain any additional labelling information required by Regualtions onplant protection or biocidal products !The supplier of a substance or a mixture within the scope of Law on Plant Protection Products or Law on BiocidalProducts shall update the label in accordance with the provisions as provided for in Article 30 of CLP/GHSRulebook.Any update to the classification or labelling of a plant protection or a biocidal product should beperformed in accordance with the provisions of the CLP/GHS Regulation (see Article 15 and 30)!DO NOT FORGET: at the same time you should also update SDS!1.7 When do I need to classify and label my chemicals in line with CLP/GHS system?CLP/GHS Rulebook applies to you if you manufacture, import, use or distribute chemical substances or mixtures.You must classify, label and package any substance or mixture, regardless of its annual tonnage, in accordancewith the CLP/GHS Rulebook before you place it on the Serbian market. The timing of the classification andlabelling of chemicals will have to be in line with the transitional provisions set out in CLP/GHS Rulebook. The8
supplier of chemicals shall also update the label in accordance with the provisions provided for in CLP/GHSRulebook.Placing on the market of a substance or mixture means making it physically available to third parties, whether inreturn for payment or free of charge.If you manufacture, import, use or distribute chemical substances or mixtures:• You must classify, label and package any substance or mixture in accordance with theCLP/GHS Rulebook before you place it on the Serbian market.Take into account transitional provisions set out in CLP/GHS Rulebook!If you export to EU:• You are required to classify substances that are subject to registration or to notification in line with REACH.This includes e.g. the classification of substances that are used for product and process-orientatedresearch and development!• You must also notify (regarding EU GHS) hazardous substances that you place on the EU market on theirown or contained in hazardous mixtures above certain applicable concentration limits, regardless of theannual tonnage imported, as well as substances subject to registration under REACH and that you placeon the EU market. However, the duty to notify does not apply in case you have already submitted theinformation which is relevant for a notification under EU GHS as part of a REACH registration. Moreinformation on notification regarding EU GHS and Inventory you may find on the website of EuropeanChemicals Agency.If you export to EU:• You are required to classify substances that are subject to registration or tonotification in line with REACH• You are required to classify substances that are subject to notification in line with EUGHS1.8 What are transitional periods for classification and labeling of chemicals in accordance withCLP/GHS system?Transitional provisions are set out in Article 38 of CLP/GHS Rulebook, defining essentially two target dates thataffect the classification, hazard communication and packaging of hazardous substances and mixtures, namely 1October 2011 and 1 June 2015.More detail information shall be added only in Serbian language by colleagues from Chemical Agency!1.9 What are my obligations regarding DSD/DPD system of classification and labelling in thetransitional period – do I have to classify and label according to both systems (DSD/DPD andCLP/GHS) in the transitional period?The main obligation imposed on manufacturers and importers of substances, downstream users, includingformulators of mixtures and re-importers of substances or mixtures is to classify, label and package substancesand mixtures in accordance with the CLP/GHS Rulebook. Distributors (including retailers) of substances andmixtures need to label and package in accordance with CLP/GHS Rulebook.Importers into EU (or groups of importers) who place a hazardous substance on the EU market will also have tonotify certain information, in particular the substance identity and the classification and labelling of that substanceto European Chemicals Agency (ECHA), unless this information has already been submitted as part of aregistration under REACH. ECHA will then include the notified information in the Classification & Labelling9
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GHS (CLP/GHS system) IN PRACTICE - Agencija za hemikalije

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