Questions and Answers

The Publications Office of the EU publishes useful information Regulation (EC) No. 1272/2008 on classification, labelling and packaging (CLP) of substances and mixtures on its website. This lists amendments to CLP and also includes consolidated versions.

However at the end of last year I got into an “issue” with a supplier over the latest application date of a harmonised classification and labelling (CLH) change for formaldehyde.

There was a change to the CLH published in the 6th Adaptation to the Technical Progress (ATP) to the CLP (Commission Regulation (EU) No. 605/2014) which required that the revised CLH be implemented by 1 April 2015.

The consolidated version of the CLP dated 1 June 2015 does show the revised classification and I cannot trace on the EUR-Lex a later ATP to CLP that revises this.

However, a supplier insisted that the latest application date for this change in respect of mixtures was 1 June 2016.

Can you clarify the position please?

According to Article 33 of the CLP regulation, when you are shipping products which are hazardous under CLP, but which aren’t dangerous goods for transportation, you have to add the CLP label to the outer packaging. In this case, which language(s) does the label have to be in? Does it need to be in the languages for both shipping and receiving country, or only for the receiving country?

For years I have been using 100mm x 100mm Hazard Class 9 labels with the outer line being a dotted line and the inner line a solid line. Should the labels actually measure 110mm x 110mm, with the inner line being 100mm x 100mm?

I have been told by a German customer that the German language of some of the P statements on the CLP labelling I have recently generated and asked them to approve is not correct. I took the text from the 1 June 2015 consolidated version of the CLP Regulation obtainable on the EUR-Lex website, so I can’t understand why they claim it is not correct. Can you please explain what the issue may be?

Annex XVII of the consolidated version of REACH makes reference to a number of hazard class numbers, such as “Hazard Class 5.1”, that I cannot find any mention of within CLP Annex 1. Am I missing something?

Following a review of risk assessments and current health surveillance arrangements, we have decided to introduce a health surveillance programme for dermatitis for a number of employees. Could you outline the factors to consider in such a programme?

Are there any official thresholds that define when aqueous solutions of common acids and alkalis must be classifiable as Corrosive to Metals, for both supply and transport purposes?

Are there specific restrictions on including non-dangerous goods in the same package with dangerous goods when these are to be transported by road in the UK? If so, where can I find the reference(s)?

Do I have to apply a CLP label to each layer of a package, including the outermost layer on the package shipped to the recipient? The product is not classified as dangerous for transport, only hazardous for supply.

We have a hazardous for supply (but not transport) solid chemical product that is packed inside a sealed liner and placed inside a receptacle that is closed with a large lid.

To make the product suitable for selling in many EU Member States (MSs), is it permitted to enclose a sheet with the hazardous labelling information communicated in many languages inside the lid, with a brief mention of this on the outside of the receptacle in each applicable language?

The justification is that the user will need to remove the lid and will therefore invariably come across the hazardous information sheet before accessing the hazardous materials.