Labelling of lubricants and mineral oil products according to CLP
Principles
The label on the packaging of hazardous chemicals should provide essential information on the hazards and the most important precautionary statements to persons who handle a substance or a mixture (new term for ‘preparation’).
The Globally Harmonized System of classification and labelling of chemicals (GHS) has been agreed within the United Nations (UN) with a view to facilitate international trade while protecting human health and the environment. In the European Union (EU) the worldwide GHS is implemented by the CLP Regulation (EC) No 1272/2008 which was published on 31 December 2008 and came into force on 20 January 2009. CLP stands for ‘Classification, Labelling and Packaging of substances and mixtures’. The Regulation (EC) No 1272/2008, the amendments of CLP by so-called ATPs (Adaptation to Technical Progress) and the corresponding ECHA Guidances are available on the website of ECHA (European Chemicals Agency):
http://echa.europa.eu/regulations.
There are different transitional periods for substances and mixtures for the implementation of the CLP Regulation: • since 1 December 2010 substances and • from 1 June 2015 mixtures have to be classified and labelled according to CLP.
The CLP classification and labelling is already permitted since 20 January 2009.
Mixtures which were placed on the market with the labelling according to the Dangerous Preparations Directive (DPD) before 1 June 2015 need not be re-labelled according to CLP until 1 June 2017. Basically, there is only one labelling for mixtures on packagings permitted within the transitional periods, either according to old law (DPD) or new law (CLP).
The required labelling according to CLP for substances and mixtures placed on the market within the deadlines is under the responsibility of the suppliers. Meeting the CLP obligations for labelling is not only relevant for the manufacturers and importers of chemicals but also for formulators, refillers and distributors.
In addition to the new label, CLP effects the information in the safety data sheet, whose requirements are defined in Annex II of the REACH Regulation. As of 1 June 2015 the CLP classification and labelling of mixtures shall be stated in section 2 (“Hazards identification“) of the safety data sheet; this came already into force for substances on 1 December 2010. It is necessary to ensure that the information in section 2 of the safety data sheet comply with the CLP label.
Labelling according to CLP According to the CLP Regulation a substance or a mixture classified as hazardous, which will be placed on the market, has to be labelled with elements shown in Figure 1 demonstrated on an example mixture.
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LUBE MAGAZINE NO.126 APRIL 2015
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