Regulatory Updates: What to Expect in the Second Amendment to CLP Annex VIII

ECHA held a Webinar on 12th February covering topics surrounding creating notifications to the poison centres in accordance with CLP Art. 45, Annex VIII.  The webinar consisted of two parts – regulatory updates and IT tools and guidance. The previous blog post focused on changes in the first amendment to CLP Annex VIII. In this blog post, we will focus on regulatory updates that we can expect in the second amendment of Annex VIII to CLP.

Second Amendment – Issues Under Consultation

Following discussions from a workability study, the Commission is working on a draft revision following comments from stakeholders. The last consultation will be on 31st March 2020. ECHA expects that the second amendment will be published mid-July this year.

Here’s some of the suggested solutions that came out of the discussions on workability issues:

  1. Interchangeable components
    Components that are different but are sufficiently similar due to having the same technical function, same physical and health hazards, same acute toxicological effects, and same hazard identification can be considered as interchangeable.
  2. Standard formulations for mixtures with raw material of natural origin
    As it is more important for components of natural origin to meet defined standards rather than chemical composition, it is difficult to know the exact composition of the mixture containing such components. In cases like this, it is suggested to notify such standard formulas and deviate from the default limits outlined in Annex VIII.
  3. UFI for base can be used for mixtures formulated at point of sale
    Another issue that was discussed was mixtures that are only formulated at point of sale. For example, paints at a home improvement store. In this case, it is not required to notify the final mixture sold. Rather, the UFI of the base paint and the tinters can be affixed on the final mixture. However, should the concentration range exceed the threshold, the concentration range of the tinters must also be displayed.

While this were some of the topics mentioned during the webinar, it’s best to refer to the ECHA Poison Centres website for the latest updates. If you’d like to recap on some of the topics in the first amendment to CLP Annex VIII, see our previous blogpost.

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