The EU Classification, Labelling and Packaging (CLP) Regulation, together with the REACH Regulation, is the cornerstone of the EU chemical legislation. Changes to CLP will have an impact on regulatory management under REACH (e.g. identification of substances of very high concern, restriction & authorisation of chemicals) as well as on product-specific EU legislation (e.g. cosmetics, biocidal and plant protection products, toys etc.). Having analysed the current European Commission proposal for the revision of the CLP, we believe that the following improvements are needed:
- Do not rely only on “structural similarity” to classify groups of substances as it is not supported by scientific evidence.
- Keep definitions aligned with REACH and established practice to provide regulatory certainty for businesses
- Keep a 18-month implementation period for all label updates
- Keep formatting rules for labels flexible.
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