Changes in product labeling due to REACH and CLP
By end of November 2010 many “high volume” substances (acrylates, PI’s, additives etc) have been registered under the European REACH regulation. During this registration process, the substances have been thoroughly evaluated and their classification and labeling has been established. For this all available tox and eco-tox studies have been reviewed and, where indicated, new studies have been conducted. As per Dec 1, 2010 the new CLP regulation for substances has come into force, the hazard information (symbols, statements) are now different than the ones used up to now (DSD). As a consequence the new C&L for many of these substances might be more severe compared with the existing one due to the more stringent CLP classification rules or due to new test data generated for REACH. Please note that for mixtures (preparation) the CLP system is not mandatory but can be applied on a voluntary base. Regarding deadlines and further details on the CLP regulation please see the link to the ECHA website or contact the RTE HSE committee.
In the near future, consortia of manufacturers and importers of substances used in the UVEB industry may start publishing their list of substances registered in 2010 with their new CLP hazard information. Regarding acrylates it is the PARAD acrylates consortium (at REACHCENTRUM) that has published a list of acrylates with their registration deadline and soon including the CLP data (see link). Please note that exactly this labelling is mandatory for all manufacturers and traders handling the same substances in the EU!
In view of the CLP notification process, RTE and other in the UVEB industry involved associations have worked to agree on a common C&L of frequently used substances not yet registered under REACH. The involved companies have looked at the available studies of each substance and made the respective conclusions. It has been agreed to apply the agreed C&L until further data is available and these substances will be registered under REACH in 2013 or 2018. At the same time these C&L were notified to ECHA. Enclosed you find a list of PI’s with their agreed and harmonized C&L information. This list was elaborated by the RTE CIG of manufacturers and importers. Also the UVEB acrylates sector group of CEFIC will publish a list of widely used acrylates with their harmonized C&L (see link below).