CLP Next Steps Include Public Inventory Lists

CLP Regulation passed a major CLP deadline on January 3, 2011.  CLP stands for Classification, Labeling and Packaging of chemicals. It’s a legal obligation affecting manufacturers and distributors doing business in Europe.

The European Chemicals Agency, ECHA, said that 3,114,835 notifications of 24,529 substances for the Classification and Labelling Inventory, either hazardous or subject to REACH registration, were submitted by the midnight Jan. 3 deadline, as reported by Occupational Health & Safety Magazine.

For this January 2011 deadline, the most notifications came from:

  1. Germany: over 800,000.
  2. United Kingdom: over 500,000.
  3. France: nearly 300,000.

Together over 6,600 companies were notified of at least one substance.

“It went extremely well,” said Geert Dancet, Executive Director of ECHA.  “We got over three million submissions of classifications in time by the deadline [midnight, Jan. 3, 2011].  I think it’s a real success.”

Jack de Bruijn, director of risk management, said, “We will put all the information which we have received into a public version of the inventory, which we hope to have available by May of this year.  And the main aim of that inventory is actually for companies to check whether they can better self-classify their chemicals.”

The C&L inventory. The collected data will be held in a central inventory called the C&L inventory. The public version of the inventory will also include substance identifiers and any relevant specific concentration limit or multiplying factor for each substance.

According to the REACH Regulation (Article 119.1), the C&L inventory will contain

  • The classification and labeling information on substances submitted to ECHA through REACH registrations and CLP notifications.
  • A list of substances that have harmonized classification in the EU.

ECHA says that the full database will be accessible to Member State Competent Authorities, and non-confidential information in the inventory will be made public on the ECHA’s website.

“And with that increased transparency,” said de Bruijn, “we hope that we will contribute considerably to the safer use of chemicals in Europe, in particular the chemicals which are used in workplaces and by the general public.”

Again, the classification and labeling inventory will be published in spring/summer 2011.

If a company has flagged the IUPAC name confidential, and where relevant, the Agency will publish an alternative name in the public inventory.

Missed deadline. Companies that missed the deadline and are not sure what to do may contact an advisor such as Chris Nowak at Actio for ideas that are particular for each unique business situation.  To handle the situation directly — use the CLP notification web page, which is what you would use whether you’re late notifying or not.

If you missed the deadline but act quickly, penalties may be minimal or nonexistent.  ECHA wants you to notify.  There is every impetus for ECHA to make CLP notification as reasonable as possible.  Remember: this is a relatively new mind-set as well as project to manage, so no question is too small or naive.  There are few experts, so start where you are, ask questions, and share what you learn with others who are probably wondering, too.

Background on CLP. Classification, Labeling and Packaging regulation relates to chemical substances and mixtures. It introduces into the EU the criteria of the United Nations Globally Harmonised System — also known as GHS conversion — toward classifying and labeling chemicals.

One aim of the CLP regulation is to improve the protection of human health and the environment. One way of protecting human health is by publishing criteria for defining when a substance or mixture displays properties that lead to its classification as “hazardous.”

It’s too bad the CLP Regulation has such a complicated name — the concept is quite simple.

The CLP big picture is that hazardous chemicals and mixtures, when registered under REACH Regulation, require some sort of uniform classification system; this way all participants are using consistent terms, measurement units, and pictographs. Simple.

CLP is a legal obligation, yes, but it’s also common business sense.  Of course we would would want uniform communication standards in terms of classification, labels, and packaging when it comes to hazardous materials. It sounds cost-effective, too.  OSHA estimated last year that GHS, for instance, would result in time-to-market ROI, international trade cost reduction, and savings resulting from greater job safety and less injury.

Also, we should consider cost savings from lean operations resulting from streamlined processes; never mind cost-savings in time, paper and clerical labor, and the priceless ease-of-reporting to stakeholders such as the EPA, REACH agencies, any regulatory bodies, customers, board members, the public at large.

Finally,  in standard communication documents, there are significant risk management returns to consider. No entity is really resisting CLP or GHS because it makes sense from an Environment, Health and Safety or EHS angle, as well as from the business side.

Long live the green!  Both sides of it: for the environmental stewardship folks and for the Finance department.

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About Kal

Kal Kawar, CIH, PE, has a bachelor's in chemical engineering and a master's in industrial hygiene. His professional experience includes serving as staff industrial hygienist for IBM's New York semiconductor manufacturing facility, and as industrial hygienist for IBM’s US headquarters. Now executive vice president of Actio, Kal taps more than 20 years' worth of chemical engineering, industrial hygiene, and environmental engineering experience. His far-reaching expertise with global regulatory challenges created by EPA, TSCA, REACH, RoHS, WEEE – and hundreds of others – aid in developing Actio software solutions for MSDS management, raw material disclosure compliance, and product stewardship in a supply chain.

One thought on “CLP Next Steps Include Public Inventory Lists

  1. I’d like to add a quick note to mention that the number 24,529 given for substances notified has been corrected by ECHA as of today. The actual number of substances is: 107,067. Here are the details:

    Corrigendum to the CLP statistics [from ECHA, the European Chemicals Agency]

    The 3.1 million Classification and Labelling notifications received by ECHA cover a total of 107,067 substances and not 24,529 as published on 4 January.

    The change in number is because a small number of bulk files were incorrectly counted as single substances, while in fact they contained notifications for many distinct substances. The discrepancy was identified during the initial analysis of the submitted Classification and Labelling notifications.

    The receipt of Classification and Labelling notifications under the CLP Regulation is an ongoing process. Manufacturers and importers placing on the market a hazardous substance on its own or in a mixture, or a substance subject to REACH registration, shall notify its Classification and Labelling within one month to ECHA. Therefore, the number of notified substances and notifications received will continue to increase and will be updated regularly.

    For more, go to

    Just keeping things honest! Best wishes, everyone. Contact me or leave a comment with any questions.

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