Following the publication of the European Commission’s proposal for the revision Classification, Labelling and Packaging (CLP) Regulation, Cefic releases its latest position paper on the topic: while the draft text provides some legal clarity, few elements still fall short of strengthening and simplifying the legal framework for chemicals.

CLP, together with the REACH Regulation, is the cornerstone of the EU chemical legislation. Revising CLP means changing the foundation of one of the most comprehensive chemical legislations in the world.

CLP is also interlinked with other key chemical regulations, such as product-specific EU legislation and international Global Harmonised System of Classification and Labelling (UN GHS), from which CLP is derived. Changes to CLP have a cascading effect on those as well.

Cefic supports most elements of the current proposal, as it provides legal clarity on several topics. For example, it includes a framework for labelling responsibility for online marketplaces, and rules for reporting to poison centers. The following elements, however, can be improved:

• Assuming that substances with a similar molecular structure have the same properties and the same impact on health and environment and therefore deserve a “similar classification”. This approach is incorrect as similar substances can vary substantially in their “behaviour” so we call for the use of all available data on the substance’s physico-chemical, ecotoxicological and toxicological properties to make this “similarity” assessment.
• Introducing a new definition of “multi-constituent substances.” This clashes with the approach taken under REACH, which has provided a stable and reliable foundation for chemical regulation in the EU.
• Not all rules for classifying substances and mixtures have been released yet. This lack of clarity has an impact on the stakeholders, who need to re-classify and re-label their products.
• New rules for labels formatting are too stringent and too specific.
• The new proposed deadlines for labels updates are too short for the industry to implement changes.

REACH THE FULL POSITION PAPER ON THE REVISIN OF EU LEGISLATION ON HAZAR CLASSIFICATION, LABELLING AND PACKAGING OF SUBSTANCES AND MİXTURES (CLP) HERE.