You’ve probably seen or heard the term “CLP” before, but may not know exactly what it is. CLP is an EU chemical regulation, short for Classification, Labelling and Packaging of Substances and Mixtures, with an important, albeit somewhat hidden role in the EU policy discussions. But CLP’s time trapped is the shadows is about to end. The regulation is going to be revised into a more omnipotent framework – and you can help forge it.
A key aspect of the Chemicals Strategy for Sustainability is the principle “one substance – one assessment”. The idea going forward is that the discussions and decisions on hazardous properties of substances – currently being held and made in different fora depending on whether the substance falls under REACH, food packaging, pesticides, biocides, or another category – are all going to take place under the umbrella of CLP. Once a substance is classified under CLP, regulatory action will be triggered automatically.
Key improvement: Additional hazard classes and criteria
An important part of the CLP revision is that new hazard classes, with their own criteria, will be included in the regulation. Currently, there are only classification criteria for carcinogenicity, mutagenicity and toxicity to reproduction, along with aquatic toxicity, skin and respiratory sensitization, and a few other hazard classes.
Companies are obliged to test their chemicals for these hazardous properties and provide the information on packages and labels. One way to do this is through so called pictograms – symbols of dead trees or fish, sculls, exclamation marks, and other images meant to illustrate the hazard.
Hazardous properties that trigger regulation, but are not yet identified under CLP, include Endocrine Disrupting Chemicals (EDCs), Persistent, Bioaccumulative and Toxic / very Persistent and very Bioaccumulative (PBT/vPvB), and Persistent, Mobile and Toxic / very Persistent and very Mobile (PMT/vPvM).
The European Commission and related committees are currently working to establish legal criteria for identifying such properties. We at ChemSec are active in those discussions, having experience from identifying these hazardous properties for our SIN List.
Professionals and consumers – make your opinions known!
In addition to the discussions being held in different committees, there is now an opening for everyone to have their say through a public consultation, open until the 15th of November. The consultation consists of two parts, which is quite interesting and unusual. One part is aimed at professionals, for the purpose of developing scientific criteria, but the initial part contains questions addressed to the average citizen, such as:
- Would you be willing to pay more for a product without certain hazardous properties?
- How important is it for you to know about the hazardous properties of chemicals in a product?
- When is animal testing acceptable?
In addition, there are a lot of questions about which kind of information you want as a consumer, and how you would like it to be provided.
An important step towards transparency and phase-out
At ChemSec, we welcome the CLP revision and the inclusion of new properties. We find it especially important to:
- Establish classifications for EDCs, PBTs/vPvBs and PMTs/vPvMs. This is an important step towards phasing out these chemicals.
- Increase transparency on chemical content and hazard properties in supply chains, but also for the general consumer, to help them make informed decisions.
Based on the results from the public consultation, the Commission is expected to present a revision proposal before the summer of 2022. After this, the proposal will be discussed by both the EU parliament and the Council of ministers before it is adopted.
In other words, we have quite a long way to go before we reach our destination of an all-inclusive CLP. But if you want to make your voice heard as this omnipotent regulation takes shape, there is no time like the present to answer the public consultation.
