CLP Regulation: New classifications are here!

Preliminary versions of the CLP Regulation have been available for some time, and since 31 March 2023 it is official: new classifications are coming in Europe [1]. We will go through the most important key data in this blog post.

What new classifications are being added?

These classifications are new:

• Endocrine disruption to human health (EUH380 and EUH381)
• Endocrine disruption to the environment (EUH430 and EUH431)
• PBT / vPvB (persistence, bioaccumulation, toxicity, EUH440 and EUH441)
• PMT / vPvM (persistence, mobility, toxicity, EUH450 and EUH451)

I will write more detailed articles about the individual classifications in the future.

Are there any new labelling elements?

As the new classifications are European classifications for the time being, they cannot be found in the GHS. However, the GHS specifies the pictograms, H phrases and P phrases. Therefore, the dangers of the new classifications are described in EUH phrases which are H phrases that are only valid in the EU.

The amending regulation [1] mentions that additional communication via pictograms is desirable, but is only possible when the new classifications are part of UNGHS.

In the end, this means that the already mentioned EUH phrases are assigned to be used in Europe. In addition, suitable P phrases are also indicated, which are relevant for the label and section 2.2 of the safety data sheet. However, H phrases / pictograms do not exist for the time being without the adaptation by GHS.

New classifications are here, what now?

There are of course transition periods, as usual with legislative changes that have mainly new or heavily modified elements such as new classifications. These are helpful and useful to give manufacturers and the supply chain time to supplement the new classifications on their own products.

In the context of the classifications, other properties also become particularly relevant, such as the log KOC value (indication of the amount of organic carbon in water).

The transition periods

The transitional periods are not described at the beginning of the Amendment Regulation, but directly in the subsections of the various classifications. The deadlines indicate the period of time after which the classification and labelling must also correctly contain the new classifications. If mixtures have already been placed on the market, they must still be relabelled after the expiry of the last deadline, if the labelling should apply according to the new classifications.

The dates:

Transition period for substance classifications and labelling: Until 01.05.2025

Transition period for mixture classifications and labelling: Until 01.05.2026

Transitional period for mixture labelling if already on the market: Until 01.05.2028

Safety data sheet creation with software

These transitional periods are also important for us as a manufacturer of software for the creation of SDS. Now that the exact description of the classifications and label elements are known and official, we immediately set to work to make these new classifications available for substances and mixtures.

Sources:

[1]        Official Journal of the European Union, Volume 66, L93,  from page 7