Introduction of the CLP Regulation
Since June 2015, the classification and labelling according to the CLP Regulation has also applied to mixtures. Containers with the old labelling can still be found in different businesses. Find out here what companies and organisations need to consider.
An overview of the changes
- Since 1st June 2015, all newly manufactured mixtures have to be classified and labelled according to the CLP Regulation and include safety data sheets according to the current Annex II of Regulation (EC) No. 1907/2006 (REACH Regulation).
- Goods that were classified and labelled according to the old law, could, in principle, be sold (bought) until 31st May 2017. However, since this deadline has expired, all mixtures, which are issued to third parties, have to be classified according to the CLP Regulation and provided with new identification labels and legit safety data sheets.
- According to the Hazardous Substances Ordinance, containers used for work with hazardous substances or within the company should primarily be labelled in accordance with the CLP Regulation.
- However, it is not compulsory to relabel containers that are used internally and are still labelled in accordance with the rules of Directive 1999/45/EEC. Possible errors (e.g. accidents, mistakes with labels) result in risks to the health and safety of employees that should better be avoided, see TRGS 201 for more information. Those who have old stocks that are still to be marketed, should carefully consider their course of action. Placing on the market in the old format is no longer permitted.
Adaptation of businesses to the CLP Regulation
Until 31st May 2017, processing organisations could still obtain mixtures, which were labelled according to the former Preparation Directive (RL 1999/45/EC). However, after this date, all newly purchased mixtures had to be adapted to Regulation (EC) No. 1272/2008 (CLP Regulation). For safety reasons, hazardous substances and mixtures should remain in their original containers as far as possible and should not be relabelled, as long as no additional safety information has arisen, such as illegible labels or a tightening of the classification of mixture components, which means that the labelling of the previous mixture must now be corrected. Just as original containers in the plants, reserve samples, laboratory preparations or rarely needed chemicals in warehouses do not necessarily have to be relabelled (see Article 8 paragraph 2 no. 2 of the Ordinance on Hazardous Substances). This means that companies will continue to use both labelling systems simultaneously for some time. To ensure the required occupational safety in companies, they must ensure their employees understand both systems during their simultaneous use.
To provide internal support, the TRGS 201 Classification and Labelling of Activities involving Hazardous Substances (in German language) can be consulted, in which the occupational health and safety regulations concerning activities with hazardous substances in relation to the CLP Regulation are described.
By the way, containers that are sold by companies to third parties must comply with the classification and labelling rules of the CLP Regulation at the latest after the expiry of the sales deadline in 2017.
For further detailed information please refer to our German Website.