Classification, Labelling and Packaging (CLP)

Irish companies importing hazardous chemicals from Great Britain, i.e. England, Scotland and Wales, should be aware of their obligations under the CLP Regulation (EC) No 1272/2008 on the classification, labelling and packaging of substances and mixtures, hereinafter referred to as CLP.

Implications for Irish companies sourcing hazardous chemicals from Great Britain from 1 January 2021

As of 1st Jan 2021, an Irish company sourcing chemical products from Great Britain is an EU importer, and thus responsible for ensuring that hazardous chemical products are compliant with CLP.

Responsibilities for importers of chemical products under CLP include:

• ensuring that chemical products are classified, packaged and labelled according to CLP criteria * . The EU supplier details must be provided on the label
• notifying, where relevant, information on the classification and labelling of imported substances, on their own or in a mixture, to the classification & labelling inventory at ECHA within one month of placing on the EU market as per Art 40 of CLP, regardless of tonnage imported
• Submitting a Poison Centre Notification for products placed on the Irish market as per Art 45 and Annex VIII of CLP (for further information see Notification to NPIC - Health and Safety Authority (hsa.ie)) and ensuring that the NPIC emergency number is included in Section 1.4 of the SDS.

*To note from 1 January 2021, the EU CLP Regulation was replaced in Great Britain by the GB CLP Regulation, which also adopts the United Nations Global Harmonised System (GHS). Therefore, most label elements such as pictograms and hazard statements should remain the same. However, there may be some differences between the EU CLP Regulation and the GB CLP Regulation. Therefore, EU importers must ensure that classification and labelling is assigned correctly for all hazardous chemical products received from GB before placing those products onto the EU market.

Ireland/Northern Ireland Protocol and the implications for the CLP Regulation

Under the Protocol, CLP applies in respect of Northern Ireland meaning that chemicals traded between Northern Ireland and Ireland must comply with all the rules set out in CLP.

Further information:

• HSA Brexit Webinar recordings
• Slides from Brexit webinar dealing with implications under CLP
• ECHAs Q&As on the UKs withdrawal from the EU & CLP
• ECHAs Q&As on the Ireland/Northern Ireland Protocol
• ECHA advice for EU based companies
• HSA webpages on CLP
• ECHAs webpages on CLP
• HSA Information sheet for Chemical Importers
• Chemical Legislation Role Finder