Page 6 - SAEOPA CLP Guidelines

Introduction
1.3 CLP and UN GHS
The UN GHS aims to facilitate global trade. The GHS is developed and maintained at United Nations level and aims to avoid different hazard information requirements on physical, health and environmental hazards for the same chemicals around the world. By applying GHS across
1.4 CLP and REACH
CLP and REACH are separate but related legislation. REACH is the Registration, Evaluation, Authorisation and restriction of Chemicals. (Regulation (EC) No 1907/2006). The focus of REACH is the registration of substances imported by, or manufactured in, the EU above 1 tonne per year. CLP concerns the notification of hazardous chemicals and there is no minimum tonnage threshold (Article 39a&b of CLP regulation).
CLP includes substances and mixtures subject to REACH registration, and REACH includes Classification and Labelling based on CLP (Annex VI). For this reason, an EU importer or manufacturer does not need to notify (under CLP) a substance that they have already registered under REACH legislation when the registration dossier includes the information to be notified under CLP.
Under REACH legislation it is possible for a non-EU company to participate in the registration process by nominating
1.5 Finding information about CLP
The European Chemicals Agency (ECHA) has prepared detailed guidance about the CLP regulation.The information in this Guideline is derived from the ECHA guidance published on its website, including Guidance documents. This Guideline draws up on the information published by
different countries, it will no longer be necessary for an exported chemical to be reclassified and relabelled to comply with different classification criteria, labelling rules and safety data sheet requirements of the importing country.
an “only representative” located in the EU to carry out the registration of their substances that are imported into the EU.The Only Representative fulfils the registration obligations of importers and complies with all other obligations of importers under REACH. There is no such similar procedure under CLP.
REACH contains the requirements for Safety Data Sheets (SDS) (see Article 31a and Annex II). An SDS is required where a substance or mixture is classified as hazardous according to the CLP regulation, irrespective of quantity imported by or manufactured in the EU. Furthermore Section 2 of the SDS has the hazard identification information: classification, hazard statements, signal word, pictograms, precautionary statements, and other hazards not classified. Therefore, Section 2 of the SDS is completed by following the requirements of the CLP regulation.
ECHA and summarises it in a few pages as an introduction for South African exporters. However, it is recommended that interested readers refer to the detailed and comprehensive guidance published by ECHA.
https://echa.europa.eu/regulations/clp/understanding-clp https://echa.europa.eu/guidance-documents/guidance-on-clp
SAEoPA | CLP GuideLines
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