by Caroline Miller, CIH, CSP
On May 4th 2018, the 11th Adaptation to Technical and Scientific Progress (ATP) to the CLP Regulation was published in the Official Journal of the European Union. Commission Regulation (EU) 2018/669 – commonly known as the 11th ATP to CLP – was originally released by the European Commission on April 16th 2018, and applies from December 1st 2019.
What changes are in the 11th ATP to CLP?
Annex VI – which is now made up of just Table 3 since the Dangerous Substances Directive (DSD) classifications were removed – was historically only available in English, even in versions of CLP available in other languages.
The 11th ATP to CLP sees these chemical names being translated formally, and suppliers should therefore revise the labelling and packaging of substances and mixtures to ensure that the new formal translations are used.
Although the regulation doesn’t take effect until December 1st 2019, suppliers may choose to utilize the new classification and labelling criteria before then.
It should also be noted that there will be no sell-through period available for products placed on the market before December 1st 2019 (as there sometimes is for other amendments to CLP).
The 11th ATP to CLP was published to have the chemical names of the substances in Annex VI formally translated. The ATP is available in multiple languages here.
It should be noted that ECHA was not involved in the preparation of the amendment, and noticed that the classification and labelling (C&L) data is not up to date. Therefore, ECHA recommends to use it for the translated names only.
Any reference to a harmonised C&L entry should still refer to the ATP where the entry was included in Annex VI. The ECHA excel file with all the C&L data for the latest ATP can also be used.
Recommended Action Item
- Review your inventory of substances imported, used or manufactured in the EU to ensure that the appropriate name translations are used.
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EU CLP Regulation 11th ATP to CLP, EC 1272/2008, Published Classifications