The Commission Regulation implementing Article 45 of CLP
The two main elements introduced by the Implementing Regulation describe a:
Harmonised format for submitting information to appointed bodies. A common EU format will gradually replace the current national information requirements. Information to be provided relates to the chemical composition of hazardous mixtures, identity and concentration ranges of ingredients, toxicological information and the product category according to a harmonised EU Product Categorisation System (EuPCS).
Unique formula identifier (UFI). The UFI is a unique code to be printed on the label of the product. It will create an unambiguous link between a mixture placed on the market and the information on that specific mixture submitted to poison centres, so that the chemical formulation of the product can be precisely and rapidly identified. A precise identification is necessary to provide appropriate curative measures in the case of an emergency call.
Submission of information according to user type
Importers and downstream users placing hazardous mixtures on the market will be responsible for submitting the required information in the Member States where the mixture is placed on the market. A distinction will be made between mixtures for consumer use, professional use and industrial use. Phased deadlines for the submission of information will apply on 1 January in a stepwise manner, depending on the intended use of the mixture:
- Consumer uses: 2020
- Professional uses: 2021
- Industrial uses: 2024.
CLP Article 45(4) Annex VIII (2): The Commission carried out the review provided for by Article 45(4) of Regulation (EC) No 1272/2008, and its findings, which were based on thorough expert consultation, were published in January 2012. The review concluded that there is considerable variation in the current notification systems, data formats and country-specific requirements regarding the requested information in the Member States. This implies that importers and downstream users placing mixtures on the market in different Member States, need to provide multiple submissions and in different formats, regarding information that is often similar. The review also showed that this diversity leads to inconsistencies in the information available to medical personnel and the general public in cases of poisoning incidents in different Member States.