CLP | Reach Impact

The Classification, Labelling and Packaging Regulation

What is is about?

Harmonised Classification and Labelling:
The Detriment for a Successful Authorization

The Classification, Labelling and Packaging Regulation (EC No 1272/2008) (CLP Regulation), together with the REACH Regulation (LINK), is the key piece of EU legislation on chemicals.

CLP Regulation aims to ensure a high level of protection of health and the environment, as well as the free movement of substances, mixtures, and articles.

For businesses, it is a cornerstone regulation as it may predetermine the success of an authorization of a substance. For example, if a substance has a cut-off classification (e.g. carcinogenicity, mutagenicity, or reproductive toxicity category 1), often, only a lengthy and even less unpredictable derogation to the standard approval process could ensure the substance remains on the market.

What is going to change:
Review of CLP Regulation – Revision brought fundamental changes

The Revision of the CLP Regulation is now finalized. The aim was to update the Regulation in light of new scientific and market developments, as well as to achieve the objectives of the Chemicals Strategy for Sustainability and the Green Deal (LINK to new text).

The revision of the Regulation notably introduced:

new hazard classes and criteria, including the endocrine disruption category,
clarification on the obligations to classify mixtures and some complex substances,
specific rules for online sales,
a mandate for the Commission to request for ECHA & EFSA to develop new harmonised classification and labelling (CLH) dossiers.
an obligation to provide information of some hazards on the label for products who used to be outside the scope of CLP, allowing multilingual fold-out labels,
tailored labelling rules when there is not enough space on the packaging.
Priority for harmonised classification for a group of substances
Speeding up the CLH process

How we can help?

The EU’s Classification, Labelling, and Packaging Regulation, (EC) 1272/2008 (CLP Regulation), is well meant but can pose a significant regulatory challenge to the future of your business. EPPA provides political and regulatory advocacy with the objective of facilitating appropriate, harmonised classification that prevents jeopardising certain future commercial uses of the active substances in the EU and abroad.

Examples in which regulatory advocacy can support your case:

Harmonised classification processes for pesticide active substances approved under Regulation (EC) 1107/2009. EPPA helped numerous agro-chemical companies to achieve milder classifications and even a unique re-classification of a cut-off, classified substance towards less adverse classification.

How EPPA can specifically support your business:

Crafting dedicated strategy, applying specifics of your case to political and socio-economic realities thanks to socio-economic analyses and tailored policy & political approaches.

At each stage addressing the right officials at the appropriate levels, with your message in the right materials.

Strengthening your scientific dossier with the help of a large network of independent experts.

Building a consistent, socio-economic and risk-benefit narrative of your case to mobilise impacted Member States.

Covering the majority of Member States’ competent authorities with dedicated outreach with regulatory and scientific arguments supporting your case thanks to our large network in all EU Member States.

Why EPPA?

With more than three decades’ experience, having worked on dozens of active substances with EU institutions, member states’ governments, and private sector stakeholders, EPPA assists its clients to facilitate adverse effects of the CLP Regulation and proposes and implements unique strategies in support of clients’ cases.

Attentive listening, a dedicated, experienced team, thorough quantitative and qualitative analysis and close collaboration are the cornerstones of our service for many satisfied clients ranging from large multinationals to family-owned niches.