CLP Art. 45 Annex VIII: Shift of the Consumer Use Deadline?

Word has it that there is a possible postponement of the January 2020 deadline for notification of consumer use products to the poison centers under the CLP Art. 45 regulation. We too have received hints of the shift from January 2020 to January 2021 from various stakeholders who attended the CARACAL meeting in July such as ECHA, as well as from some of our customers who are active in industry associations, and national poison centers.

How does this affect my company?

Deadline change possible

While a change of deadline would certainly do all of us a favor, it is by no means final. We at opesus like to err on the side of caution. Hence our advice – continue IT projects as planned and don’t delay implementations. Even if the deadline is postponed, there is still plenty of work required. It’s to your advantage to be ahead in the game.

A takeaway from the successful projects with our customers: determining the quality of data as well as preparing data for the PCN format takes time. With some planning ahead, you’ll be well on your way to comply with the poison center requirements on time.

No official communication

As long as no new deadline has been published in the Official Journal of the EU, the deadline on 1 January 2020 remains valid. The member states are in consultation on the draft of CLP Directive Art. 45 Annex VIII and are expected to conclude sometime in November. Even after that, the European Parliament and European Council may still raise objections, which could delay a decision even further. If you want to have a closer look at the possible changes to CLP Art. 45 Annex VIII you can find the proposal for the amendments to Annex VIII and the justification for the amendments on the website of the European Commission.

If you would like to find out more about further developments, check back with us for the latest news. Until then, we’d be happy to speak with you on the best approaches to ensure that your portfolio is compliant with the CLP Art. 45 Annex VIII regulation. Contact us here.

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