how to comply with clp
Share |

Roles and Obligations under CLP

The obligations of a supplier of a substance or mixture depend upon his role under CLP. Please identify your roles in the supply chain and your obligations in the following table.

Role in the supply chain

Obligations under CLP

 

EU manufacturers and EU importers of substances or mixtures

- should classify, label and package substances and mixtures according to CLP before placing them on the market;

- should notify the classification and labeling elements to the classification and labeling inventory established by ECHA before 3 Jan 2011(C&L Notification Is Required);

- ECHA has indicated in its FAQs that if you missed C&L notification deadline, you shall notify without any delay to avoid legal penalties. You can avail of our CLP notification service by using our application form.

More info can be found at:

http://echa.europa.eu/clp/info_clp_companies_en.asp

- should update the label following any change to the classification and labeling of that substance or mixture

- should submit a proposal to the Competent Authority if you have new information which may lead the change of harmonized classification and labeling.

- shall provide Safety Data Sheets(SDS) along the supply chain and update SDS when necessary.

EU producers or importers of explosive articles

- should classify, label and package this article according to CLP before placing it on the market

- shall provide SDS along the supply chain and update SDS when necessary

Downstream users (including formulators and re-importers)

- should classify, label and package substances and mixtures according to CLP before placing them on the market; may also take over the classification, provided that you do not change the composition of this substance or mixture;

- should update the label following any change to the classification and labeling of that substance or mixture;

- should submit a proposal to the Competent Authority if you have new information which may lead to a change in the harmonized classification and labeling;

- shall provide SDS along the supply chain and update SDS when necessary;

Distributors(including retailers)

- should classify, label and package substances and mixtures according to CLP before placing them on the market;

- should take over the classification for a substance or mixture already derived  by another actor in the supply chain in accordance with Title II of CLP , for example from a Safety Data Sheet.

 

Note: Non-EU companies and REACH only representatives do not have direct obligations under CLP regulation. However, non-EU companies might be required to provide the latest Safety Data Sheet according to REACH & CLP or submit C&L notifications for each of its importers. The most urgent thing for EU importers/manufacturers of chemicals at the moment is to submit C&L notifications before 3 Jan 2011.

If you are a non-EU company and your importers have requested you to submit C&L notifications, we may also submit C&L notification in the name of your EU importers and acquire C&L notification number for them.

How can we assist you in complying with CLP?

We provide end-to-end solutions to CLP compliance. We can help you classify your substances and mixtures according to CLP, notify the classification and labeling of your products to the C&L Inventory, prepare CLP compliant labels and the latest Safety Data Sheets.

Even though there are many guidance documents on how to prepare CLP compliant label, it is much easier and less time-consuming for you to outsource this job to us.

  • Regulatory advice on the implications of CLP and REACH for your company;
  • Re-classification and re-labeling of your substances or mixtures;
  • Preparation of CLP compliant labels;
  • Notification to the Classification & Labeling Inventory (C&L notification);
  • New Safety Data Sheets in accordance with CLP & REACH;

About CIRS

CIRS a leading provider of comprehensive chemical compliance services for companies doing businesses in/with EU and China with a strong focus on chemical compliance.

With a strong presence in EU and China, CIRS has provided cost-effective regulatory support to over 3,000 companies while doing businesses in both the EU and China.

CIRS is the largest REACH only representative in the world. Since 2007, we have:

  • pre-registered over 10,000 substances;
  • acted as only representative for over 2,400 non-EU companies;
  • served clients in more than 25 countries;
  • registered over 145 substances to date;
  • prepared over 1000 REACH SDS and CLP labels to date;
  • submitted over 500 C&L Notifications to date;

    •  

CIRS is a recommended service provider by China Inspection and Quarantine Bureau, the US Mission to the EU and IDA. CIRS is also a member of Helsinki REACH Centre.

Contact

CIRS also offer CLP compliance package price (notification+SDS+label) from 300 Euros per substance. We also prepare Chinese MSDS and label in accordance with China GHS.

  • Europe Office
    Unit 1 Ardee Business Park, Hale Street, Ardee, Co. Louth, Ireland
    Tel : +353 41 9806 916 | Fax : +353 41 9806 999
    Email: service@cirs-reach.com