Update to EU CLP Annex VI Published

Earlier this month an update to Annex VI of the EU CLP was published. Annex VI of the EU CLP regulation (EU CLP regulation = EU’s adoption of GHS) provides mandatory substance classifications for some substances. This part of the EU CLP regulation is updated about once a year to keep up with new information on the hazards of chemicals that become available.

Name of the Regulation – COMMISSION REGULATION (EU) 2017/776 of 4 May 2017 amending, for the purposes of its adaptation to technical and scientific progress, Regulation (EC) No 1272/2008 of the European Parliament and of the Council on classification, labelling and packaging of substances and mixtures

Link to the text – http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32017R0776&qid=1494492161138&from=EN

Commentary/Analysis – does not mention “ATP ##” in the same manner as past ATPs have typically done.  This may make referencing the changes more challenging and something that will need to be discussed.

Effective date – 12/1/2018; but any of the classifications and changes can be considered prior to this date

Summary of Changes

  • Since the old regulations (DSD and DPD) are officially sunset as of June 1 this year –
    • Table 3.1 is now just Table 3 throughout the regulation
    • References to old regulations have been removed where appropriate
  • Table 3 now includes ATEs for some substances and also includes a change the column headers to include ATE
  • Note 8 is added –The classification as a carcinogen need not apply if it can be shown that the maximum theoretical concentration of releasable formaldehyde, irrespective of the source, in the mixture as placed on the market is less than 0,1 %.
  • Note 9 is added – The classification as a mutagen need not apply if it can be shown that the maximum theoretical concentration of releasable formaldehyde, irrespective of the source, in the mixture as placed on the market is less than 1 %.
  • 13 entries are changed & 24 are added new