CLP Art. 45: Commission Adopts Deadline for Consumer Use to 1st January 2021

Last week ECHA announced that under the CLP Art. 45, Annex VIII, the poison centre deadline for mixtures intended for consumer use is postponed to 1st January 2021. The compliance dates for professional and industrial use remain the same.

You might think, “That’s great! We have more time!”

We don’t doubt that this is great news. However as mentioned in our earlier post, we like to err on the side of caution.

This means that if you had placed your IT project for CLP Art. 45 regulation for poison centre notifications on hold, it’s time to get them back on track. In short, don’t delay implementations.

In our experience of over 50 implementations of opesus EHS Product Notification (EPN) to support the poison centre notification (PCN) format , we recognize the same issues reoccurring. Our advise: do not underestimate the time required to fill data gaps and improve data quality to the necessary level. The PCN format demands a lot of data points.

Plan for time to manage data quality

In addition to that, protecting your confidential business information often requires additional work. Considering the intricacies of the UFI and reporting of mixture compositions, you will need to hold several internal discussions to decide how UFIs should be generated and how this affects the overall business process.

While our software helps you identify the data gaps easily, data maintenance and decision making require time. For example, many of our customers had to check how they maintain pH values or how to map packaging information to the allowed ECHA values.

Not sure how to get started? Contact us. We’d be happy to speak with you on the best practices to ensure that your portfolio is compliant with the CLP Art. 45, Annex VIII regulation.

For the official press release by ECHA, click here.

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