Since 1 June 2015, substances and mixtures alike must be classified and, where required, labelled in accordance with CLP before they are placed on the market. There was a two-year derogation for mixtures already labelled under the Dangerous Preparations Directive (DPD) and placed on the market by that date, which allowed them until 1 June 2017 to reach the end user without the need to be re-labelled. Beyond 1 June 2017 mixtures labelled under the DPD needed to be relabelled in accordance with CLP. But for any new batches of existing formulations, as well as newly designed mixtures, CLP applies in its entirety. The key tasks which importers and formulators of such mixtures should focus on are:
- Classifying mixtures according to CLP before placing them on the market;
- For imported hazardous mixtures, notifying the component ingredients that are responsible for the hazard classification to the Classification and Labelling Inventory;
- Labelling all mixtures classified as hazardous, or which require labelling in accordance with Annex II;
- Updating all relevant documentation, including safety data sheets, websites, catalogues, advertisements etc with the new CLP classifications.
- Notifying any hazardous mixtures placed on the market and classified as hazardous on the basis of their health and physical effects to poison centres.
This document introduces the methods available to classify mixtures under CLP and discusses how it differs from classifications under the DPD.