EU Adapts Global Harmonized System of Chemical Labeling

Knowing the potential dangers to humans and the environment that arise from chemicals and the fact that they are transported worldwide, the UN recognized the need for a common classification and labeling system. In 1992, the United Nations Conference on Environment and Development (UNCED) provided the international mandate to achieve this task. The first version of The Globally Harmonized System of Classification and Labeling of Chemicals (GHS) was adopted in December 2002, and the World Summit on Sustainable Development in Johannesburg of 2002 encouraged countries to implement the new GHS as soon as possible with the goal of having the system fully operational by 2008. After two amendments in 2004 and 2006, the second revised edition of the GHS was ready for worldwide implementation.

The European Union integrated the implementation of GHS within its process of introducing REACH. Whereas the registration provisions of REACH entered went into effect in 2007, GHS still went through stakeholder consultations and assessment processes. REGULATION (EC) No 1272/2008 on classification, labeling and packaging of substances and mixtures (CLP) was adopted and published in December 2008. The act aligns existing EU legislation to the GHS and assumes Title XI (Classification and Labeling Inventory) from the REACH Regulation.

The new regulation entered was enforced two weeks ago, on Jan. 20, 2009. It stipulates that the deadline for reclassification of substances is Nov. 30, 2010, and May 31, 2015, for mixtures. As of June 2015, the old frameworks Directive 67/548/EEC, Dangerous Substances Directive, and Directive 1999/45/EC, Dangerous Preparations Directive, will be repealed.

Similar to the old legislation, the new regulation is primarily a self-classification system for companies. Hazardous chemicals are identified and users are informed of their presence through standard symbols and phrases on the packaging labels, and through safety data sheets (SDS).

Classification and labeling of substances of special concern is given in the EU harmonized list in Annex VI of the CLP Regulation. Table 3.1 of Annex VI gives classification and labeling entries in accordance with the criteria of CLP, whereas the entries in Table 3.2 apply to the criteria of the Dangerous Substances Directive and replace Annex I of this directive as of Jan. 20, 2009. Annex VI contents are legally binding and will be updated by Adaptations to Technical Progress (ATP).

Member state competent authorities, manufacturers, importers or downstream users can make a proposal for harmonized classification and labeling of a substance to be included in Annex VI of CLP. In accordance with the procedure laid down in the CLP regulation, the proposal should be submitted to the European Chemicals Agency (ECHA). The Committee for Risk Assessment of ECHA will then adopt an opinion on the proposal and forward it to the Commission for a possible inclusion in an ATP.

Further questions? Go to C&T’s REACH Round Table.

EU Joint Research Center, formerly European Chemicals Bureau
UNECE-United Nations Economic Commission to Europe on GHS

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