May 18, 2021
By Eleanor Grimes, PhD
On April 20, 2021, the European Commission released the latest update to the Classification, Labelling and Packaging (CLP) regulations ((EU) 2021/643). These are the first changes that will not be automatically adopted by the U.K.
Compared to more recent updates, these are small phrasing changes to Notes J-R and 8-9 that provide considerations for specific entries to the Annex VI list. In general, these notes mostly affect UVCB (unknown or variable composition, complex reaction products or of biological materials) substances, such as petroleum oils, and cover the right to amend a harmonized classification if it can be proven that specific impurities are present at low enough concentrations.
The changes to the text as stated are relatively minor and have been designed to remove the inaccuracies and uncertainty about the correct interpretation of legal obligations that were present in the previous wording. In particular, the new wording enhances the need for the person undertaking the classification to undergo the full classification process for the substance and not just remove the additional hazards and assume the product is not required to be labeled.
Due to the size of the impact, the regulation enters into force 20 days after its publication on May 10, 2021.
Recommended action item
- Evaluate the classification of any substances you have that use these notes as part of their harmonized classification and make sure you are interpreting them correctly.