Practical CLP Compliance Advice for Importers
The CLP Regulation, Article 46, on Enforcement and Reporting, states that “Member States shall take all necessary measures, including maintaining a system of official controls, to ensure that substances and mixtures are not placed on the market, unless they have been classified, labelled, notified and packaged in accordance with this Regulation”.
Main Obligations of EU Importers under CLP Regulation:
- Urgent: to notify the classification and labeling elements to the classification and labeling inventory established by ECHA before 3 Jan 2011; 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:
- to classify, label and package substances and mixtures according to CLP before placing them on the market;
- to update the label following any change to the classification and labeling of that substance or mixture;
- to submit a proposal to the Competent Authority if new information which may lead to a change of the harmonized classification and labeling;
- to provide Safety Data Sheets (SDS) and pass them along the supply chain and update SDS when necessary.
To comply with CLP, EU importers shall do the following four things:
- Chapter One: Classification
- Chapter Two: C& Notification
- Chapter Three: Labeling and Packaging
- Chapter Four: Safety Data Sheet
Download full article here[pdf,280KB]
"Something importers should know about C&L notification"
- Substances that will be registered by your suppliers under REACH before 30 Nov 2010 do not require C&L notifications;
- Non-EU companies and REACH only representatives are not entitled to submit C&L notifications;
- C&L notification is cheap and easy. It is much easier and less time-consuming if you could outsource this job to us. We provide this service at only 150 Euros per substance. Discount is available for multiple substances;
- Our recommendation to EU importers is that you shall submit your own C&L notifications as the first choice. If you do not know how to submit C&L notifications, please contact us to help you fulfill your obligations under CLP;
- If you request your non-EU suppliers or the only representatives of your suppliers to submit C&L notification for your company, what they actually do is to create REACH-IT account for your company and submit C&L notification in the name of your company. Your company name will be on the submission report. "
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
We offer free consultation services on cost estimation. If you would like to find out how much it might cost to register your substances, please consult:
- 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 - Ms. Alice Qian, China Office
11F Building 1, Dongguan Hi-Tech Park, 1288 Chunbo Road, Binjiang District, Hangzhou 310052, China
Tel: +86-571 8720 6555 | Fax: +86-571 8720 6533
Email: info@cirs-reach.com