by Heidi Bramblett, MPH
Industrial Hygienist

The European Union (EU) CLP (Classification, Labelling, and Packaging) Regulation falls under the broader framework of chemical regulation in the European Union. The primary legal basis for the CLP Regulation is Regulation (EC) No 1272/2008.

This regulation, more commonly referred to as the CLP Regulation, aims to align the EU system for the classification, labeling, and packaging of substances and mixtures with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS). The GHS is a globally recognized system developed by the United Nations to standardize the communication of hazards associated with chemicals.

The CLP Regulation covers the classification criteria for chemical hazards, labeling requirements and packaging standards. It also addresses the harmonized communication of information on hazardous chemicals throughout the supply chain CLP outlines specific roles for different duty holders in the supply chain, including manufacturers, importers, downstream users, distributors, and formulators.

The Unique Formula Identifier (UFI) and Product Categorization Notifier (PCN) are integral components of the EU CLP Regulation. The UFI is a 16-character code assigned to chemical mixtures for precise identification in emergencies. Integrated into product labels, UFIs aid poison centers and emergency responders. The PCN requires companies to submit detailed mixture information to poison centers, enabling accurate advice during emergency calls. Together, the UFI and PCN enhance hazard communication, fostering a transparent and efficient system for managing chemical risks and ensuring user and responder safety.

How does this impact your business in the US?

There are 3 key steps in compliance:

  1. Classification, Labeling, and UFI Assignment
    Determine the classification of substances or mixtures according to CLP criteria. This involves assessing their hazards, such as physical, health, and environmental hazards. Properly label substances or mixtures with the prescribed elements, including pictograms, signal words, hazard statements, and precautionary statements. Additionally, assign a Unique Formula Identifier (UFI) to each mixture, ensuring a unique code for precise identification in case of emergencies and facilitating poison center access to relevant information.

  2. Safety Data Sheets (SDS) and PCN Submission
    Prepare and provide Safety Data Sheets (SDS) for substances and mixtures. SDS must include information on the properties and hazards of the chemicals, as well as guidance on safe handling, storage, and emergency measures. Distribute SDS to downstream users in the supply chain and update them when necessary. Simultaneously, submit a Product Categorization Notifier to poison centers, providing detailed information about the composition, hazards, and toxicological data of the mixtures. This aids poison centers in offering precise advice during emergency calls.
  1. Communication in the Supply Chain with UFI and PCN Integration
    Establish effective communication throughout the supply chain. Manufacturers and importers must communicate hazard information to downstream users and distributors. Downstream users, in turn, are responsible for using chemicals in accordance with the provided information. Distributors ensure that substances and mixtures are properly labeled before placing them on the market. Regularly update classifications, labels, and SDS based on any new information or changes in the properties of the chemicals. Integrate the UFI and PCN into the communication process to enhance emergency response capabilities and ensure swift access to relevant information in case of incidents.

In conclusion, compliance with the EU CLP Regulation involves a multifaceted approach emphasizing precise hazard communication and supports transparency and crucial information for emergency response teams. Effective communication throughout the supply chain, with the integration of UFIs and PCNs, reinforces the commitment to safety, enabling quick identification and informed decision-making in cases of exposure or poisoning incidents. By navigating these key steps, businesses not only ensure regulatory compliance but also contribute to a safer environment through consistent and transparent chemical hazard management.

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How We Can Help
At The EI Group, Inc. our safety and industrial hygiene professionals have experience assessing risk for a wide array of manufacturing clients. We would be glad to assist with your health and safety needs. If you have questions, please contact Heidi Bramblett at (919) 817-9508 or hbramblett@ei1.com.