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CLP Regulation: 2nd amendment of Annex VIII has entered into force

Update on CLP Regulation - many clarifications and some simplifications for Poison Centre Notifications

On 14 November 2020, the Commission Delegated Regulation (EU) 2020/1677 entered into force, adding a number of new items to Annex VIII of the CLP Regulation (Classification, Labelling and Packaging of Substances and Mixtures) with regard to Poison Centre Notifications (PCN) according to Article 45. In particular, it provides more clarity in cases that were previously less concise.

More precise definitions remove former ambiguity as to which of the respective deadlines applies to consumer, professional or industrial use in a given case. Moreover, "bespoke paint" is now explicitly included in the regulation and exempted from potential requirement to notify for each new mixture.

Of great practical importance for the implementation of PCN notifications are the innovations and clarifications on how to deal with raw materials of (partly) unknown composition, as well as with UFI numbers of mixtures in mixtures (MiM), which may already exist but have not yet been notified.

The newly added concept of the "interchangeable component group" can greatly reduce the required number of PCNs by formulators who use a large number of similar, frequently changing raw materials with the same technical function – avoiding an unmanageable flood of update submissions. In particular, simplifications have been introduced for mixtures that correspond to standard formulations (fuels, cements, gypsum, ready-mixed concrete) to reflect the reality of these product groups.

If you need assistance or advice in fulfilling your own PCN obligations, please do not hesitate to contact us. Our experienced team of product safety experts will be happy to help you identify your individual obligations, and to develop and implement suitable and pragmatic strategies together with you.