8 POINT ACTION PLAN FOR AN EFFECTIVE
REVISION OF THE EU CLASSIFICATION,
LABELLING AND PACKAGING REGULATION
Together with REACH, the EU Classification, Label ing and Packaging Regulation (CLP) is a cornerstone of
the EU chemical legislation. Revising CLP means changing the foundation of one of the most comprehensive
chemical legislation in the world. This 8-point Action Plan outlines how this can be done in a targeted way
so that it effectively tackles the areas where improvement is needed in line with the objectives set in the
Chemical Strategy for Sustainability.
ACTION 1: ASSESS THE IMPACT OF CLP CHANGES ON OTHER MANUFACTURING
SECTORS
WHY? Adding new hazard classes to CLP will not only affect the
?
RESULT:
chemical industry, it wil also have
a “ripple effect” on many
P • Careful analysis will help identify whether strategic
downstream sectors using chemicals due to automatic links
and essential value chains may be negatively
between CLP and sector-specific product legislation (e.g. biocides,
impacted by the CLP reform.
pesticides, detergents, cosmetics, toys, medical devices, amongst
others).
In fact, as many as
12,000 substances might be affected by proposed
changes to CLP and GRA (generic approach to risk management). As
a result, many products that consumers and professionals rely on may
no longer be available on the market.
ACTION 2: AGREE CHANGES TO CLP AT THE GLOBAL LEVEL FIRST
?
WHY? EU’s CLP is based on the United Nation Global y
RESULT:
Harmonised System of Classification and Label ing of Chemicals (UN
P • Chemical safety information remains harmonised
GHS), which is a key building block for ensuring safety of chemicals all
at the global level with no deviating regional
over the world. Making unilateral changes that deviate from the global
standards. Multiple updates of EU CLP to realign
standard
may disrupt global value chains and undermines trust
with UN rules are avoided.
in the wel -functioning global system.
While it is possible for the EU to propose an update to UN GHS
after updating CLP, there is no guarantee that it would be accepted
by all parties, meaning that
EU CLP may need to be updated
several times to realign with the international standard.
Adding new hazard classes to CLP now does not add any value from
the public health and environment perspective either: EU REACH
already regulates all substances that would be covered by adding new
hazard classes under CLP.
ACTION 3: ENSURE CRITERIA FOR ENDOCRINE DISRUPTING SUBSTANCES
REFLECT THE WORLD HEALTH ORGANISATION’S (WHO) DEFINITION
WHY? The WHO definition of endocrine disruptors represents the
?
RESULT:
global science-based foundation to identify substances with endocrine
P • Updated CLP Regulation is built upon evidence-
disrupting properties. It is also already used in the EU legislation
based criteria consistent with the rest of the EU
governing the use of plant protection products and biocides. So it is
legislation.
important to
keep this definition as a basis for future policy
for both category 1 and category 2 sub-divisions.
ACTION 4: ALLOW THE USE OF ADDITIONAL DATA TO CLASSIFY SUBSTANCES AS
“MOBILE” UNDER CLP
WHY? One of the potential changes to CLP is to identify and
?
RESULT:
label substances with Mobile (M) or Very Mobile (vM) properties.
P • Evidence-based approach is used to inform
However, the technical and policy discussions over the past
decisions concerning this “difficult-to-identify”
years have confirmed the
absence of a reliable and robust
hazard class.
methodology that would make it possible to decide whether a
substance can qualify as Mobile or Very Mobile. For this reason, we
need to use additional data and “weight of evidence” approach.
ACTION 5: BETTER PROMOTE THE USE OF DIGITAL SAFETY LABELS
WHY? CLP revision is an opportunity to modernise the label ing of
?
RESULT:
packaging. In addition to keeping essential safety information on the
P • Digital formats will make labels more consumer-
physical labels,
making more use of digitalised labels would
friendly by giving consumers an opportunity to
make it possible to provide additional information about hazards,
receive even more information about the safe use
safety, and product composition in many various languages online.
and in many more languages than one physical
label
• Less crowded labels make safety information
easier to read and to understand by users.
ACTION 6: ENSURE SUFFICIENT TRANSITION PERIODS TO IMPLEMENT CHANGES
WHY? The introduction of new hazard classes will require
?
RESULT:
reclassification and new label ing of all substances. Once substances
P • All manufacturers have sufficient time to
are reclassified and relabel ed, mixtures of substances will have to be
implement changes.
reclassified and relabel ed in turn.
Formulators of mixtures first need al new classification information
on substances before they can update safety information for
mixtures. Therefore,
two distinct and successive transitional
periods for substances and mixtures are needed: at least two years
for substances and three years for mixtures.
ACTION 7: ENSURE ONLINE MARKETPLACES COMPLY WITH CLP AND ENFORCE
COMPLIANCE FOR ONLINE OPERATORS
WHY? Online marketplaces are not defined as “economic
?
RESULT:
operators” nor “importers”. As a result, EU Member State authorities
P • Making online platforms responsible for the goods
cannot enforce EU chemicals safety laws for goods sold
they sell will
enhance consumer safety.
online, especial y if online marketplaces are registered outside of the
EU.
ACTION 8: ENSURE THE EUROPEAN CHEMICALS AGENCY HAS SUFFICIENT RE-
SOURCES AND EXPERTISE TO IMPLEMENT CHANGES
WHY? Adding new hazard classes to CLP will require the European
?
RESULT:
Chemicals Agency (ECHA) and Member States to significantly
P • ECHA has the manpower and expertise to deliver
increase their resources to handle the workload and process
on policy goals and implementation.
new requirements. ECHA’s Committee for Risk Assessment (RAC)
will also need to develop new areas of expertise to provide advice on
new hazard classes.
