Business in chemicals in the EU is different and more complex because of REACH and CLP regulations that are inherently more complex. CLP regulation defines criteria for labeling, classification, and packaging of hazardous chemicals in the EU, whether these are for industrial use or for consumer use, even chemical products used in small quantities. CLP is wider in scope as it covers end users and effects on the environment in greater detail.
It becomes even more complex when the GHS hazard classification in CLP/REACH applies to a hub sector specific classification of specialty chemicals as are grouped in annexure VI. It requires careful consideration. Part I relates to list of harmonized classification and labeling. Part 2 defines guidelines for document preparation and part 3 lists the hazardous substances. It requires an expert to unravel the complexities of the document and arrive at the right classification category. One must take into account index numbers, EC numbers, CAS numbers and international chemical identification of a hazardous substance.
In addition to taking care of exceptions that might require the substance to be classified under another head, one must also consider the percentage of a chemical in a formulation. In some cases, some substances may fall into several group entries in which case the most severe classification applies. The various hazard classes are explosive, flammable gasses and aerosols, the oxidizing gas, gasses under pressure, flammable liquids and others including germ cell mutagenicity and carcinogenicity. Hazard statement codes apply to each substance and its classification. Labeling codes are also quite well defined and must conform to annexure V with the use of appropriate signal word code, hazard statement code as specified in annexure III and codes for supplemental statements pursuant to article 25(1). It becomes more complex to understand and apply since there are qualifications such as when a chemical is stabilized by the use of an additive in which case it may need to be classified under another head. In short, the REACH and CLP registration process impose strict regulatory requirements for chemical import and distribution, especially if they are specialty chemicals with impact on human health and environment.
Companies that wish to export to the EU must not only ensure full compliance and prepare and exhaustive document but they must also ensure that such documents are translated into local languages without losing any of the meaning in the process of translation. In cases where formulations are proprietary then it requires special expertise to present and prepare documents as well as obtain the exemption from declaring the secret while remaining in full compliance, a no mean task. This is where employing experts to take care of CLP GHS hazard classification and documentation comes in useful.
ECHA not only prepares all the guidelines for harmonized classification but these are constantly updated and this is yet another reason to hire experts who keep themselves updated with latest modifications and updates to Regulation (EC) 1907/2006 and 1271/2008 for the European Union.
