2022/0432(COD) · In Force
314 submissions from 251 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission received 352 submissions on this file. Shown here: the 314 from organizations. Not shown: 33 from private individuals. Their submissions are personal data; the Commission publishes them under its own legal basis, and republishing them by name here would need one we do not have. Organizations act in a public capacity, so their positions are public record. Also not shown: 5 further submissions we do not publish for other reasons: no quotable text (a comment under 250 characters and no readable paper), no organization named, or a private person who filed under their own name. About this data →
237 submissions from industry — companies and their trade associations — against 38 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 6.2 industry submissions for every one from civil society.
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice. An identical text filed by several organizations counts once: 1 submission here repeats one text word for word and is folded into it.
What the room declares
Self-declared to the EU Transparency Register (snapshot 14 Sept 2026). The cost figure sums band floors, so the true total is higher.
The file, right now
The consultation closed on 30 Mar 2023 — it ran from 20 Dec 2022.
How it got here
Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned.
Showing 25 of 314 submissions.
· · filed 30 Mar 2023 · source
The Danish Association of Cosmetics and Detergents welcomes the opportunity to give feedback to the legislative proposal of the CLP Regulation. In particular, we would like to highlight the following items that we find important to point out: - The industry is already dedicated to reduce the use of packaging, and therefore it is welcomed warmly that criteria for refill sales are articulated in the proposal.
Revisión Rto UE CLP Ref. Ares(2023)2320208 - 30/03/2023 29/03/2023 Propuesta de revisión del Reglamento UE sobre clasificación, etiquetado y envasado de sustancias y mezclas químicas (CLP) ANTECEDENTES Este texto se elabora con motivo de la consulta de la CE sobre la Propuesta de revisión del Reglamento UE sobre clasificación, etiquetado y envasado de sustancias y mezclas químicas (CLP). Aquí.
Filed in Spanish · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 30 Mar 2023 · source
APQuímica appreciates this opportunity to express its views and make contributions regarding the legislative proposal to amend the EU legislation on classification, labelling and packaging of substances and mixtures (Regulation (EC) n.º 1272/2008 CLP Regulation) included in the EU Chemicals Strategy for Sustainability (CSS) under the EU Green Deal.
The Endocrine Society welcomes the opportunity to comment on the proposal to amend Regulation (EC) No 1272/2008 of the European Parliament and of the Council on classification, labelling and packaging of substances and mixtures (CLP).
1 Ref. Ares(2023)2319276 - 30/03/2023 IndustrieGaseVerband e.V. · Französische Straße 8 · 10117 Berlin IndustrieGaseVerband e.V. Französische Straße 8 10117 Berlin Telefon [phone removed] Fax [phone removed] [email removed] industriegaseverband.de 30.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
BASA CLP Consultation Response March 2023 Thank you for the opportunity to give feedback on the proposals to amend Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures. BASA, The British Adhesive and Sealants Association are concerned about some of the elements of the recent CLP proposal on labelling.
Revision of EU legislation on hazard classification, labelling and packaging of chemicals – EPSON’s comments March 2023 Article 30 par.１ 6-month transitional period to update the label is quite short and we would strongly call on the authorities to set longer period of time.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Thank you for the opportunity to give feedback on the proposals to amend Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures. IFRA UK has some comments about this which we would like to set out. They are contained within the attached document.
· · filed 30 Mar 2023 · source
The European Society of Endocrinology (ESE) welcomes the current legislative proposal which will contribute towards creating a non-toxic and safe EU environment as laid out in the Chemical Strategy for Sustainability.
TT Environmental Ltd is a specialist safety and environmental consultant serving the EU and UK chemical industry. We train people in CLP labelling, and also run a self-help group for regulatory discussions, so we are aware of many difficulties with the labelling changes proposed in this revision of CLP.
Representing more than 100 suppliers of fertilisers and innovative inputs of sustainable crop crops, AFAla is the trade union of operators in the cultivation media, mulching, organic soil improvers, organic and organo-mineral fertilisers and biostimulants sector. In general, AFAla can only welcome this initiative.
Filed in French · English published by the European Commission
With regard to the revision to the CLP Regulation, and the documents published on the 19th December 2022, FIPEC would like to share the following comments on four important topics: Regarding transition periods and definition of placing on the market (OLP text and Delegated Act), once again, we call to take into account the need for sufficient time for mixture manufacturers to act with respect to relabelling and…
Evergreen Garden Care is a passionate 800+ strong team, dedicated to ensuring that domestic gardeners of all experience levels can easily grow and protect their lawn, plants, fruits or vegetables and create their own green oasis. With market-leading brands like Miracle-Gro, Fertiligene, Substral and Pokon, we deliver a full range of garden care products to gardeners throughout the majority of Europe.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 30 Mar 2023 · source
Cosmetics Europe is the European trade association for the cosmetics and personal care industry whose key priority is to ensure that consumers have access to safe, innovative, and sustainable cosmetics and personal care products, while maximizing the potential of the industry for innovation and growth.
· · filed 30 Mar 2023 · source
The revision of Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures aims to improve the identification and classification of hazards and the provision of information on the occurrence of health hazards in the handling of chemicals. The German Statutory Accident Insurance (DGUV) is therefore very much welcome to regulate online sales of chemicals.
Filed in German · English published by the European Commission
The LOCCITANE Group shares and supports the Commissions aims of ensuring consumer safety and environmental protection. However, the LOCCITANE Group believes that an integrated approach to scientific rigor, environmental protection and consumer and producer safety necessitates proportionate, appropriate, and specific regulatory measures depending on the substances for example essential oils.
EFEO comments on the revision of CLP 2022/0432(COD) EFEO welcomes the opportunity to provide comments on the legislative proposal amending Regulation (EC) No 1272/2008 of the European Parliament and of the Council on classification, labelling and packaging of substances and mixtures published on December 19th, 2022.
FEBEA brings together and represents more than 300 manufacturing companies selling cosmetics in France and internationally within the meaning of Regulation (EC) No 1223/2009 (perfumes, make-up, hairdressing products, care products and hygiene and toilet products), which are marketed through numerous distribution systems.
Filed in French · English published by the European Commission
Merck Life Science thanks the Commission for the opportunity to comment. We believe the proposed revision of CLP may constitute something of a missed opportunity to improve on labelling and communication and currently works counter to some of the stated aims of the revision.
Feedback to the Commission consultation on the CLP revision 30 March 2023 As the Classification, Labelling and Packaging (CLP) Regulation is one of the cornerstones of the EU chemicals legislation along with the REACH Regulation, it is imperative that the revision will improve the current CLP while not creating unnecessary regulatory burden or rules which in practice would not be implementable or hamper the…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
With the planned introduction of the new hazard classes Endocrine Disruptors (ED); Persistent, bioaccumulative and toxic (PBT); very persistent and very bioaccumulative (vPvB); Persistent, Mobile and Toxic (PMT) and very persistent and very mobile (vPvM) within the scope of the EU, the EU is even more distant from the globally valid and recognised Globally Harmonised System (GHS).
Filed in German · English published by the European Commission
We welcome the Commission’s proposal to revise the Regulation on Classification, Labelling and Packaging (CLP), which aims to make labelling more consumer-friendly, less burdensome for suppliers and easier to enforce.
Filed in German · English published by the European Commission
EFPIA, the European Federation of Pharmaceutical Industries and Associations, represents the innovative biopharmaceutical industry operating in Europe. We would like to reiterate our strong support for the overarching objectives of the CSS (Chemical Strategy for Sustainability) and welcome the opportunity to provide feedback on the open public consultation on the Revision of the Regulation on Classification…
EFCC fully supports the intention of the European Commission to improve identification and classification of hazardous chemicals and welcomes the opportunity to participate in the public consultation on the revised Regulation on CLP.
Cabrières d’Avignon 29th of March 2023 FEEDBACK ASSESSMENT FROM AROMA-ZONE Hazardous chemicals – updated rules on Classification, Labelling and Packaging AROMA-ZONE, as a member of the Essential Oil Consortium welcomes the opportunity to provide comments on the legislative proposal amending Regulation (EC) No 1272/2008 on the Classification, Labelling and Packaging of substances and mixtures (CLP).
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
We as a company welcome the opportunity to contribute constructively to the goals of the Chemicals Strategy for Sustainability. Whereas we recognize a clear and substantiated concern for the safety of human health or the environment, all stakeholders should work together in realizing a workable and proportionate solution.
EU Commission proposal for the revision of the CLP Regulation (1272/2008). Overall, the Danish Consumer Council Think welcomes the proposal, in particular the inclusion of endocrine disruptors and the simplification of consumer information. We would like to see mandatory full declaration of chemicals in articles/products on the packaging.
Filed in Danish · English published by the European Commission
The EGGER Group welcomes the possibility to submit an opinion on the European Commission’s proposal of 19.12.2022 for a Regulation of the European Parliament and of the Council amending Regulation (EC) No 1272/2008 (CLP) as part of the public consultation. While we very much welcome key approaches to the proposal, the proposal addresses serious legal concerns.
Filed in German · English published by the European Commission
Bayer Response to the Public Consultation on the Revision of the Regulation on Classification, Labelling and Packaging of Substances and Mixtures (CLP) Key Messages ❖ No CSS action should be tackled on its own – CLP revision being no exception. Impacts across the EU regulatory landscape should be appropriately considered, including all relevant sectoral legislation.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 30 Mar 2023 · source
Den Haag, 30 maart 2023 Aan Onderwerp European Commission Consultatie over Proposal for a regulation - COM(2022)748 CLP De CLP-wetgeving (gevaarsindeling, etikettering en verpakking van stoffen en mengsels) is samen met REACH de basis voor de EU-chemicaliën wetgeving. De voorgenomen herziening betekent een fundamentele verandering.
Filed in Dutch · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 30 Mar 2023 · source
Thank you for the opportunity to comment on the European Commissions proposal for a Regulation amending the Classification, Labelling and Packaging of substances and mixtures (CLP) Regulation. This submission is made on behalf of the following animal protection NGOs: Cruelty Free Europe, the European Coalition to End Animal Experiments, Humane Society International/Europe, and People for the Ethical treatment of…
The European Association of the Self-Care Industry (AESGP) expresses its full support for the overarching objectives of the Chemical Strategy for Sustainability (CSS). Furthermore, the AESGP welcomes the chance to offer feedback on the open public consultation regarding the Revision of the Regulation on Classification, Labelling, and Packaging of Substances and Mixtures (CLP).
MAVESZ welcomes the proposals of the European Commission, which aim to protect people and the environment from dangerous chemicals. In our opinion, the targeted revision of the CLP regulation can contribute to the management and reduction of the risks of substances and mixtures based on other related EU legislation, taking into account the socio-economic effects.
The Polish Union of the Cosmetics Industry supports the goals of the Green Deal. We welcome the opportunity to engage with the European Commission on the revision of the Regulation on the classification, labelling and packaging of substances and mixtures 1272/2008/EC (the CLP Regulation).
Detic is the Belgian and Luxembourgish federation of producers of cosmetics, detergents, biocides, adhesives and sealants and aerosols technology. Detic welcomes the opportunity to provide feedback on the Commissions proposed revision of EU legislation on hazard classification, labelling and packaging of chemicals (CLP).
· · filed 30 Mar 2023 · source
Green Transition Denmark (Rådet for Grøn Omstilling) welcomes the draft proposal for a revision of the CLP legislation and greets the intentions behind the proposal in order to modernise the legislation and make it more protective, efficient, and coherent.
The European Environmental Bureau (EEB) welcomes the Commission proposal on the revision of the EU regulation on hazard classification, labelling and packaging of substances and mixtures (CLP). The proposal supports the toxic-free environment vision of the European Green Deal and the Chemicals Strategy for Sustainability (CSS) and its intention to shift the focus from the use of toxic chemicals towards the use of…
ChemSec welcomes the Commissions proposal for a revision of the CLP Regulation. We share the aim of modernising and streamlining the regulation to make it more efficient and protective. However, we have some important recommendations to improve safety for consumers and the environment. We strongly supported the delegated act to include EDCs, PBTs, vPvBs, PMTs and vPvMs as new hazard classes.
MARCH 2023 Eurometaux comments: CLP Revision feedback consultation We welcome Commission’s efforts to increase the robustness and the transparency of the CLP, one of the core tools for the implementation of the Chemicals Strategy for Sustainability (CSS).
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Générations Futures welcomes the Commission proposal for a revision of the CLP legislation, and the associated delegated act amending the CLP Annexes. Générations Futures supports the goals of the Chemicals Strategy for Sustainability and the European Commissions efforts to improve the chemicals legislation to make it more protective, efficient, and coherent.
With regard to the proposed revision of the CLP Regulation, and the documents published on 19th December 2022, the European Association of Chemical Distributors (Fecc) would like to comment on various points that are critical from our point of view. Please find our comments in the attached document.
· · filed 30 Mar 2023 · source
Eurogroup for Animals welcomes the opportunity to provide feedback on the Revision of EU legislation on hazard classification, labelling and packaging of chemicals (CLP). We are the pan-European animal advocacy organisation representing more than 85 animal protection NGOs. We advocate for the protection of animals used for scientific purposes, including regulatory testing.
Ares(2023)2305552 - 30/03/2023 MINISTRY OF ECONOMY OF THE SLOVAKRef.REPUBLIC Mlynské nivy 44/a, 827 15 Bratislava 212 SK CA comment on the revision of Regulation (EC) 1272/2008 (CLP) SK CA welcomes the proposal for the revision of CLP Regulation. In general we support the proposed revision of the CLP Regulation in terms of ordinary legislative procedure.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Stellungnahme zum Vorschlag für eine Verordnung zur Änderung der Verordnung (EG) Nr. 1272/2008 über die Einstufung, Kennzeichnung und Verpackung von Stoffen und Gemischen (KOM (2022) 748) Stand: 29. März 2023 [EU-Transparenzregisternummer: 31200871765-41] Die Kommission hat am 19.12.2022 einen Vorschlag zur Änderung der sog. CLP-Verordnung vorgelegt.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 30 Mar 2023 · source
We welcome that legal clarity is provided for fuels sold at service stations. Nevertheless, we identified some practical issues with the requirements to provide the label on the pump, if label elements (e.g. Unique Formula Identifier (UFI)) need frequent updating. Likewise, we see insufficient space on the pumps to provide all the information for all the fuels (depending on the font size for the label).
Full feedback provided in attached document. Here follows a summary: Current regulations state that the required labelling information should appear clearly against the background and be easy to read. We believe that the current wording of the regulation should be retained to give companies flexibility to design their labels.
E [email removed] W etad.com T [phone removed] ETAD’s Comments on the Proposal for a Regulation amending the CLP Regulation 30 March 2023 ETAD, the Ecological and Toxicological Association of Dyes and Organic Pigments Manufactures, is a global association with a specific focus on the safety of colorants and its constant improvement.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Avis de l’Anses Saisine n° « 2023-REACh-0050 » Saisine liée 2022-SA-0169 Le directeur général Maisons-Alfort, le 28 mars 2023 NOTE d’appui scientifique et technique de l’Agence nationale de sécurité sanitaire de l’alimentation, de l’environnement et du travail relatif à la publication de la proposition de règlement du parlement européen et du conseil modifiant le règlement (CE) nº 1272/2008 relatif à la…
Filed in French · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Petroleum substances are by nature complex substances with thousands to millions of hydrocarbon constituents. They are truly substances of unknown or variable composition, complex reaction products or biological materials (UVCBs).
· · filed 30 Mar 2023 · source
Würth Assessment and Positioning on the CLP Regulation and Revision Die Adolf Würth GmbH & Co. KG would like to thank the European Commission for the opportunity to comment with a position paper on the proposal to amend the CLP Regulation.
Filed in German · English published by the European Commission
The industry association personal care and laundry detergents e.V. (IKW) supports the objectives of the European Commission to make labelling of substances and mixtures – more consumer-friendly, – less burdensome and easier to enforce for suppliers, through its proposal to amend Regulation (EC) No 1272/2008.
Filed in German · English published by the European Commission
IKEM (Innovation and Chemical Industries in Sweden) thanks the opportunity to comment on the EU Commission proposal for amendments to Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures (CLP). A revision of CLP legislation is a revision of one of the most comprehensive and deep chemicals legislation in the world.
Filed in Swedish · English published by the European Commission
· · filed 30 Mar 2023 · source
Ladies and gentlemen, thank you for your feedback on this draft amendment to the CLP Regulation. From the enforcement point of view, we provide feedback and/or questions on the following topics: The amendments to Article 29 and Article 31(3) do not clarify whether it is possible to use a folder label to house several official languages of Member States where the substance/mixture is placed on the market…
Filed in German · English published by the European Commission
Please see our position in the attached document. Our key points: The proposed approach to the classification of multi-constituent substances contradicts the UN GHS and will lead to serious implementation problems. We call for the withdrawal of the introduction of the definition of multi-constituent substances.
Filed in German · English published by the European Commission
The Union of the European Lubricants Industrys welcome the Commissions proposal to revise the Classification, Labelling and Packaging (CLP) regulation in its purpose to make labelling more consumer friendly, less burdensome for suppliers and easier to enforce.
The Danish Coatings and Adhesives Association (DFL) is grateful for the opportunity to comment on the proposed revision of the CLP Regulation. DFL welcomes the intentions behind the proposal and supports that a uniform and good information on substances and mixtures that can be purchased within the EU are ensured.
1. Introduction of new hazard classes We as Brenntag have strong concerns regarding the plan of the European Union to introduce new hazard classes into CLP Regulation without regards to the Global Harmonized System (GHS) of the United Nations.
Women Engage for a Common Future (WECF) welcomes the proposal of the EU Commission on the revision of the regulation n°1272/2008 on the classification, labelling and packaging (CLP). As an international ecofeminist network of 150 women and civil organizations NGOs, who are committed to build a healthy environment and be active and progressive on the EU level for moving towards a toxic-free future.
CHEM Trusts response to the public consultation on the CLP revision proposal Proposal for amending Regulation (EC) No 1272/2008 of the European Parliament and of the Council on classification, labelling and packaging of substances and mixtures (COM2022 748 final) CHEM Trust welcomes the Commission proposal for a revision of the CLP legislation, and the associated delegated act amending the CLP Annexes.
Comments to Consultation on Revision of EU legislation on hazard classification, labelling and packaging of chemicals (CLP) General Information Kurt Obermeier GmbH & Co. KG is a manufacturer of wood preservatives (PT 8) for the European market.
AEPLA, the Business Association for the Protection of Plants – welcomes the opportunity to provide feedback to the EC public consultation on the Revision of the Regulation on Classification, Labelling and Packaging of Substances and Mixtures (CLP) From the Plant Health Sector, we would like to highlight that chemicals legislation in Europe is one of the most stringent and complex in the world, thus ensuring very…
Filed in Spanish · English published by the European Commission
Proposta de revisão do Regulamento CLP Comentários: A proposta de revisão do regulamento CLP visa colmatar falhas nos procedimentos de avaliação e classificação dos perigos dos produtos químicos, bem como lacunas na respetiva comunicação, evitando erros na classificação e/ou classificações divergentes.
Filed in Portuguese · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
DI greets the intentions behind the proposal for securing uniformity, transparency, and compliance with other EU-legislation. Manufacturers and suppliers already deliver many different kinds of information about chemicals to customers and authorities.
Aluminium is the worlds most used non-ferrous base metal. This sustainable, versatile material allows key sectors to decarbonise and achieve otherwise impossible outcomes through its unique combination of properties and effects. Aluminium can be found everywhere: from packaging, consumer durables, and healthcare products to buildings, construction, mobility, aerospace, and energy generation.
Landesamt für Arbeitsschutz, Verbraucherschutz und Gesundheit Verbraucherschutz Stellungnahme zum Entwurf COM (2022) 748 DE Vorschlag für eine Verordnung des Europäischen Parlaments und des Rates zur Änderung der Verordnung (EG) Nr.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Feedback on: Revision of EU legislation on hazard classification, labelling and packaging of chemicals As a medium sized lubricant manufacturer we are particularly concerned about the new labelling requirements: 1. Fold-out labels Initially the European Commission wished to give more flexibility to suppliers by allowing a broader use of fold-out labels, see „explanatory memorandum“ of the proposal, page 11.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 30 Mar 2023 · source
Revision of the Regulation on classification, labelling and packaging of chemicals (CLP) Contact: [name removed] ASD views on the European Commission’s proposal to revise the Regulation on classification, labelling and packaging of chemicals (CLP) ASD is the voice of the European Aerospace, Security and Defence Industries, representing directly or indirectly (through our national association members) over 3,000…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The purpose of this document is to provide support for the use of multi-lingual fold-out labels on packages improving current hazard communication and labelling provisions. The objective of the Regulation (EC) No 1272/2008 of the European Parliament and of the Council of 16 December 2008 (CLP) is to ensure a high level of protection of human health and the environment as well as the free movement of substances, and…
AEFAA, the Spanish Association of Food Fragrances and Aromas, represents the Spanish food fragrances and flavourings industry, a strategic sector for the economy, made up of more than 36 companies. In order to safeguard the case-by-case nature of complex natural substances (essential oils, plant extracts, etc.) for continued use in perfumed consumer products and because of the great importance of this sector in…
Filed in Spanish · English published by the European Commission
COSMED, the French cosmetic association for SMEs, thanks the Commission for the possibility to comment the revision of the CLP regulation. COSMED welcomes the initiative to simplify the legal framework of chemicals but warns the Commission of the counterproductive effects of certain measures leading to overcomplexity and administrative overload for the industry, impacting even more SMEs, without any benefit for the…
· · filed 30 Mar 2023 · source
In particular, we would like to comment on the requirements of the label design. The disappearance of the coloured background removes opportunities for corporate identity. The colouriness of labels is an essential element to distinguish themselves from other companies. By changing the minimum sizes of pictograms and writings, more space is needed on labels and less multilingualism is possible.
Filed in German · English published by the European Commission
· · filed 30 Mar 2023 · source
The Hellenic Cosmetic, Toiletry and Perfumery Association (PSVAK), founded in 1964, is the Greek Association for Cosmetics and has 72 members (manufacturers, producers, and distributors). PSVAK is a member of Cosmetics Europe, the European trade association for the cosmetics and personal care industry.
Japan Cosmetic Industry Association, JCIA is representing interest of more than one thousand Japanese cosmetic companies. We would like to express our sincere gratitude to your significant efforts to protect human health and the environment from hazardous chemicals.
Being a cross-sector association with member companies operating in different industries and stages in the supply chain, JBCE welcomes the opportunity to submit its views on the feedback for the revision of EU legislation on hazard classification, labelling and packaging of chemicals. JBCE supports the risk management approach based on chemical substances and mixtures.
The Essential Oils Consortium reiterates our concern that Essential Oils, which would be considered as multi-constituent substances according to the new definition 7a introduced in article 2, should be treated as single substances and not as mixtures.
EIGA welcomes the Commissions proposal to revise the Classification, Labelling and Packaging (CLP) regulation in order to improve hazard communication and consumer safety. However, we would also like to share our comments on the Requirements for Labelling. Our concerns are explained in more detail in attached document. EIGA recommends the following options in order of preference: 1.
· · filed 29 Mar 2023 · source
At this point, the Finnish Commerce Federation wish to pay attention to few specific issues regarding the proposal to revise the CLP Regulation. In addition to what is below, we refer and express our full support to the reply of EuroCommerce. The CLP Regulation is in the hard core of EU Chemicals legislation.
ATIEL welcomes and supports the Commissions objectives for the proposal to revise the EU Classification, Labelling and Packaging (CLP) regulation to further improve the health, safety and environmental information of hazardous chemicals provided to all users of these chemicals, thus ensuring a high level of protection of human health and the environment as well as creating an efficient single market for chemicals.
· · filed 29 Mar 2023 · source
FEIQUE, the Spanish Chemical Industry Business Federation (www.feique.org), represents the Spanish chemical industry, a strategic sector for the economy, made up of more than 3.100 companies, and one of the largest and most well-established industrial sectors in Spain.
Filed in Spanish · English published by the European Commission
BSEF Comments on Proposal for a revision of the Regulation on classification, labelling and packaging of chemicals (CLP) Grouping To quote Albert Einstein: everything should be made as simple as possible but not simpler. We think that grouping should only be done where it is justified by clear scientific principles and should not be the default option.
Fher is the Federation of Hygiene and Maintenance Responsible; Fher represents in France the companies that formulate, manufacture and market products for washing, cleaning and maintaining laundry, crockery and all surfaces in households, communities, health services and industry.
Filed in French · English published by the European Commission
Eurogypsum, the association representing the interests of the European industry extracting and processing gypsum, welcomes the revision of the EU legislation on hazard classification, labelling and packaging of chemicals (CLP Regulation). Gypsum is a cost-efficient, low carbon, sustainable mineral that has been used for centuries to produce construction materials such as plaster, stucco or plaster-based products.
· · filed 29 Mar 2023 · source
Federchimica - the Italian Federation of the chemical industry groups about 1400 companies, with a total of 94.000 employees. Federchimica is divided into 17 Associations, articulated into 38 product groups. Federchimica is very interested to give its contribution to the European Commissions Proposal for the Revision of Regulation on classification, labelling and packaging of chemicals (CLP), as the proposed…
March 2023 FEEDBACK ASSESSMENT FROM THE ESSENTIAL OILS CONSORTIUM Hazardous chemicals – updated rules on Classification, Labelling and Packaging The Essential Oil Consortium welcome the opportunity to provide comments on the legislative proposal amending Regulation (EC) No 1272/2008 on the Classification, Labelling and Packaging of substances and mixtures (CLP).
Filed in French · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
March 2023 Cefic input to the EC Public Consultation on the Revision of EU Legislation on hazard classification, labelling and packaging of substances and mixtures (CLP) The EU chemical industry supports the goals of the Chemicals Strategy for Sustainability: ensure that the chemicals are produced and used in a way that maximises their contribution to society including achieving the green and digital transition…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
essenscia welcomes the opportunity to provide feedback on the Commissions proposed revision of EU legislation on hazard classification, labelling and packaging of chemicals (CLP). essenscia is the Belgian federation of the chemical, plastics and life science industry, representing 720 companies. essenscia and its members support the comments submitted by Cefic.
We welcome the possibility to provide views on the revision of the CLP regulation published on 19 December and embrace the main objectives of the revision. CEMBUREAU would like to share the following preliminary comments from members related to the minimum requirements for labels. This also appears to be a view from several stakeholders. 1.
In connection with the work on the revision of one of the most important pieces of EU chemicals legislation, the CLP Regulation, which, in addition to REACH, constitutes a regulatory pillar for a wide range of chemical substances and mixtures, as well as chemical products, is attached to the comments of the Polish Cosmetics and Detergent Industry Association (PSPKD).
Filed in Polish · English published by the European Commission
In relation to the ongoing European Commission consultation on the Revision of EU legislation on hazard classification, labelling and packaging of chemicals (CLP), on behalf of the associated stakeholders we would like to draw attention to the key issues for the chemical industry in Poland. In attached statement we have addressed some of our concerns with the current version of the text.
A.I.S.E. is committed to supporting the Chemicals Strategy for Sustainability, as part of the EUs zero pollution ambition, which is a key commitment of the European Green Deal. The targeted revision of Regulation (EC) No 1272/2008 on the classification, labelling and packaging of substances and mixtures (CLP) was identified as a key enabler for a successful implementation of the Chemicals Strategy.
1 Ref. Ares(2023)2265077 - 29/03/2023 BDZV – Bundesverband Digitalpublisher und Zeitungsverleger e. V. MVFP – Medienverband der freien Presse e. V. Rückmeldung zum Vorschlag der Europäischen Kommission für eine Verordnung zur Änderung der Verordnung (EG) Nr. 1272/2008 über die Einstufung, Kennzeichnung und Verpackung von Stoffen und Gemischen (Stand: 28.03.2023) I.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 29 Mar 2023 · source
Ladies and gentlemen, thank you very much for the possibility of providing feedback on this draft. From the point of view of its tasks in relation to the prevention of accidents at work and occupational diseases, the Department of Chemistry and Chemicals of the Department of Accident Prevention and Control of Occupational Diseases of the AUVA main body would be able to provide a brief feedback on the current…
Filed in German · English published by the European Commission
· · filed 29 Mar 2023 · source
EMMA-ENPA written contribution to the Commission’s consultation on the proposed revision of the legislation on the classification, labelling and packaging of chemical substances and mixtures (Regulation (EC) no 1272/2008 of the European Parliament and of the Council) 1. Introductory remarks The free and independent press is financed to a considerable extent by advertising.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
VCH Stellungnahme zum „Vorschlag für eine Verordnung zur Änderung der Verordnung zur Einstufung, Kennzeichnung und Verpackung von Stoffen und Gemischen (CLP)“ Hiermit möchten wir, der Verband Chemiehandel e.V., gerne zu den für unsere Mitglieder wichtigsten Punkten unsere Kommentare abgeben.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
In its comments, the Zentralverband der deutschen Werbewirtschaft e.V. (ZAW) confines its comments to the requirements of the planned amendments which are relevant to the commercial sector. This concerns the proposed amendments to Article 48 of the CLP Regulation. Please refer to the attached document.
Filed in German · English published by the European Commission
The Health and Environment Alliance (HEAL) welcomes the draft proposal for a revision of the CLP legislation and overall shares a positive assessment of the set of measures put forward by the European Commission in order to modernise the legislation and make it more protective, efficient, and coherent. Our detailed observations and recommendations are provided in the attachment.
Komentář Hospodářské komory České republiky k Návrhu NAŘÍZENÍ EVROPSKÉHO PARLAMENTU A RADY, kterým se mění nařízení Evropského parlamentu a Rady (ES) č. 1272/2008 o klasifikaci, označování a balení látek a směsí Obecně připomínky k Návrhu Nařízení Revize nařízení CLP vyjasní některá sporná ustanovení, doplní je nebo je přizpůsobí vědeckému pokroku.
Filed in Czech · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
LANXESS fully supports the aims of the CLP Revision to better identify and classify hazardous chemicals, to improve communication on chemical hazards and to address legal gaps and high levels of non-compliance. We therefore welcome the measures proposed in the draft legal text regarding digital labelling, the labelling of substances and mixtures in very small containers as well as the clarification of provisions…
Pranarom, as member of the Essential Oils Consortium welcomes the opportunity to provide comments on the legislative proposal amending Regulation (EC) No 1272/2008 on the Classification, Labelling and Packaging of substances and mixtures (CLP).
Mengend Nederland is committed to contribute constructively to the goals of the Chemicals Strategy for Sustainability. Whereas we recognize a clear and substantiated concern for the safety of human health or the environment, all stakeholders should work together in realising a workable and proportionate solution.
EuroCommerce welcomes the opportunity to provide feedback on the Commissions proposed revision of EU legislation on hazard classification, labelling and packaging of chemicals (CLP). EuroCommerce is the principal European organisation representing the retail and wholesale sector. It embraces national associations in 27 countries, , sector associations and leading global players.
Japan Chemical Industry Association (JCIA) appreciates the opportunity to provide the following comments in response to the proposal of amending CLP regulation. JCIA supports the EU's efforts to strengthen the Chemicals Management under the Chemicals Strategy for Sustainability (CSS).
With regard to the proposal for a Regulation amending Regulation (EC) No 1272/2008 published on 19th December 2022 [2022/0432 (COD)] we would like to share the attached comments on small containers such as ink refill, ink cartridge, correction fluid, paint in bottles, crayons which we acknowledge qualify as mixtures.
1 Ref. Ares(2023)2242759 - 28/03/2023 BDZV – Bundesverband Digitalpublisher und Zeitungsverleger e. V. MVFP – Medienverband der freien Presse e. V. Rückmeldung zum Vorschlag der Europäischen Kommission für eine Verordnung zur Änderung der Verordnung (EG) Nr. 1272/2008 über die Einstufung, Kennzeichnung und Verpackung von Stoffen und Gemischen (Stand: 28.03.2023) I.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 28 Mar 2023 · source
The unilateral introduction of the new hazard classes in the EU via a delegated act, while the inclusion of these hazard classes in the UN GHS is currently under discussion, will at best lead to a multi-annual transition period for non-harmonised requirements in the EU. In the worst case scenario, discussions at UN level lead to diverging requirements from those implemented in the EU.
Filed in German · English published by the European Commission
March 2023 FEEDBACK ASSESSMENT FROM THE ESSENTIAL OILS CONSORTIUM Hazardous chemicals – updated rules on Classification, Labelling and Packaging The Essential Oil Consortium welcome the opportunity to provide comments on the legislative proposal amending Regulation (EC) No 1272/2008 on the Classification, Labelling and Packaging of substances and mixtures (CLP).
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
AnimalhealthEurope is the voice of the animal health industry. Together we protect the health and welfare of over one billion animals across Europe, including both farm and companion animals. The veterinary sector not only protects animal health but also contributes to protect public health and to the production of safe, affordable and sustainable food.
The proposed amendments of the CLP regulation are very important for our industry, as they affect one of the central regulatory frameworks. The attached Eurocolour position paper comments on the most relevant issues we see in the proposal.
Position of the German Industry Federation e.V. (BDI) on “Proposal for a revision of the Regulation on classification, labelling and packaging of chemicals (CLP)” Prof. Dr. Herbert Bender Referent Umwelt ,Technik und Nachhaltigkeit 1. General Statements Date: 27.03.2023 We reject entirely any unilateral implementation of new hazard classes before they had been implemented in UN-GHS.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 27 Mar 2023 · source
CIHEF and PPAM de France welcome the opportunity to provide comments on the legislative proposal amending Regulation (EC) No 1272/2008 of the European Parliament and of the Council on classification, labelling and packaging of substances and mixtures published on December 19th, 2022. Please find attached our detailed position.
Defining Lighters under REACH/CLP By Dr. Benedikt Fischer 1 Contents 1.Introducing Ramboll............................................................................................................................. 3 2.Definition of Lighters ........................................................................................................................... 3 3.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 27 Mar 2023 · source
The Essential Oil Consortium welcomes the opportunity to provide comments on the legislative proposal amending Regulation (EC) No 1272/2008 on the Classification, Labelling and Packaging of substances and mixtures (CLP).
Filed in French · English published by the European Commission
· · filed 27 Mar 2023 · source
Multi-constituent substances IFRA would like to reiterate our concern that Natural Complex Substances (NCSs) (multi-constituent substances according to the new definition 7a introduced in article 2),should be considered as single substances and not mixtures. By nature, and definition, NCSs are complex.
With regard to the proposal for a Regulation amending Regulation (EC) No 1272/2008 published on 19th December 2022 [2022/0432 (COD)], the European Writing Instrument Manufacturer's Association (EWIMA) would like to share the following initial comments from our members. Please find our feedback in the attached document.
Or comments (short version, please see also our attached position paper for details): VSI requests the Commission to amend the transition period of 18 months to a more realistic timeframe of 36 months; it is pertinent to have a longer transition period similar to when EU CLP for substances and mixtures was implemented.
· · filed 27 Mar 2023 · source
I believe the proposed update to font sizes to be detrimental to the general public. The issue of consumer safety with respect to chemical safety labelling is more about understanding than readability and legibility. For packages that are greatly below the 3L size e.g. a 150g candle (approx 180ml), the warning label currently has not just CLP information but also product safety information that must be displayed.
The draft amendment to the regulation prepared by the European Commission indirectly sets out new environmental and chemical safety objectives and standards for operators in most sectors, including agri-culture. The Commission intends to include new hazard classes in the CLP Regulation. These would classify substances not on the basis of specific effects, but on the basis of modes of action or properties.
Filed in Hungarian · English published by the European Commission
· · filed 24 Mar 2023 · source
As a manufacturer of detergents mainly for private domestic use, we have the following comments on the draft amendment of 19 December 2022 to Regulation (EC) No 1272/2008: Article 1(11a) (amending Article 29(1)): In the way the proposal is formulated, this would not lead to more flexibility, but would only compel the use of folding labels upstream.
Filed in German · English published by the European Commission
9 March 2023 BASF feedback to the public consultation regarding the revision of EU legislation on hazard classification, labelling and packaging of chemicals BASF thanks the European Commission for the opportunity to provide feedback on the recently published draft on the revision of EU legislation on hazard classification, labelling and packaging of chemicals.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
CropLife Europe (CLE) welcomes the opportunity to provide feedback on the open EU COM public consultation on the Revision of the CLP and would like to draw attention to the following: - Multi-constituent substance and mixture classification rules: Multi-constituent substances shall be classified following the same classification, labelling, and packaging rules as mixtures.
Alzchem Trostberg GmbH Dr.-Albert-Frank-Str. 32 83308 Trostberg Germany www.alzchem.com Statement of Alzchem Trostberg GmbH on Proposal for a revision of the Regulation on classification, labelling and packaging of chemicals (CLP) Alzchem Trostberg GmbH has the following comments and concerns regarding the current Commission proposal for revising the CLP regulation: General comments Amendments in CLP…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
CLP Ltd & CHCS Response to Proposed Changes to EU CLP 2022/0432 Ref. Ares(2023)2115420 - 23/03/2023 1. Annex I Minimum Font Size (Table 1.3), Typesetting (1.2.1.5) & Article 31(3) • These are significant changes to labelling provisions which will take time to implement.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 23 Mar 2023 · source
As a multinational company, serving the EU market with various products classified as hazardous, we are very concerned regarding the new provisions for CLP Annex I Section 1.2.1.4 and 1.1.2.5 as laid down in the proposal.
· · filed 23 Mar 2023 · source
Article 1(11): Folding labels for multi-lingual packaging must be designed for marketing in several Member States. Article 1(12): Updating labels for mixtures is not feasible in only 6 months. An additional period of at least 12 months and a further 18 months is required for retail sale. Article 1(20): The classification and labelling inventory is useless and burdensome and should therefore be abolished.
Filed in German · English published by the European Commission
AmCham EU welcomes the opportunity to provide feedback on the targeted revision of Regulation (EC) No 1272/2008 for Classification, Labelling and Packaging of substances and mixtures (CLP). This is an important pillar of the Chemicals Strategy for Sustainability (CSS).
Ladies and Gentlemen, We support and support all measures that promote the safe use of chemicals and protect people and the environment. Efficient risk communication is a prerequisite for this. Therefore, we also welcome the revision of the CLP Regulation. However, the proposed minimum font size requirements on labels run counter to the objective and even lead to a deterioration of risk communication.
Filed in German · English published by the European Commission
The European Commission has adopted a proposal to revise the Classification, Labelling, and Packaging (CLP) Regulation, confirming the ambitions laid out in the proposals inception impact assessment by including provisions aiming at better identifying and classifying hazardous chemicals, and improving communication on chemical hazards, including that by online suppliers.
The attached position paper of Deutsche Bauchemie comments on the new requirements for the layout of CLP labels and the application of fold-out labels: The proposed provisions on the layout of the CLP label would lead to an immense burden, considerably restrict the urgently needed flexibility, whereas they are not necessary for a functioning of hazard communication.
· · filed 20 Mar 2023 · source
zu Nr. 10: die Frist für die Aktualisierung der Kennzeichnungsinformationen im Falle einer Anpassung der Einstufung entsprechend dem Ergebnis einer neuen Bewertung sollte ab dem Tag der neuen Festlegung weiterhin 18 Monate betragen. Kleine Firmen kaufen Jahresmengen an Etiketten, um wirtschaftlich arbeiten zu können.
We support the proposal to amend the CLP regulation with the aim of strengthening and simplifying the legal framework for chemicals to ensure a toxic-free environment. CLP should remain the main instrument for identifying and communicating hazardous properties of substances and mixtures. We propose that the new formatting requirements for label elements specifies the size of the font in millimeters.
This is a short summary of the key points of the VCI position on the CLP revision. Additional information and detailed assessments of the EU Commission's drafts is available in the attached document. General comments -Amendments in CLP Regulation concern several regulations: The legal consequences of the proposed changes for other chemical regulations, like REACH, biocides or cosmetics regulation, must be considered…
The Essential Oil Consortium welcome the opportunity to provide comments on the legislative proposal amending Regulation (EC) No 1272/2008 on the Classification, Labelling and Packaging of substances and mixtures (CLP).
· · filed 17 Mar 2023 · source
European Aerosols is a leading supplier of coating products in aerosols and 12 ml touch-ups and other technical products. We market our products in total Europa. We produce a huge variety of colors serving the car repair and for the Do-It-Yourself market. Aerosols and touch-ups are environmentally efficient tools for the repair. They are used by consumers as well as by professionals.
As a horizontal piece of legislation, CLP has a wide-ranging impact, with any change likely to have a knock-on effect on various sectors, including but not limited to biocides, pesticides, detergents, cosmetics, toys, and medical devices. For example, CLP Self-classification of substances is being included in horizontal regulations to trigger requirements without an assessment of impacts (e.g.
Brussels, 17 March 2023 Position Paper on the Revision of the CLP Regulation BeST The Beryllium Science and Technology Association (BeST) represents the suppliers of beryllium metal and beryllium containing alloys in the EU market and has the objective of promoting sound policies, regulations, science and actions related to the safe use of beryllium and to serve as an expert resource for the international community…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Verband der deutschen Lackund Druckfarbenindustrie e.V. VdL Comments to Consultation on Revision of EU legislation on hazard classification, labelling and packaging of chemicals (CLP) With regard to the proposed revision of the CLP Regulation, and the documents published on 19th December 2022, we would like to comment on various points that are critical from our point of view.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 16 Mar 2023 · source
The Czech Chemical Industry Association supports the revision of the CLP Regulation, which will clarify some of the contested provisions, supplement them or adapt them to scientific progress. This concerns, for example, notification of information on mixtures under Annex VIII, online sales or new forms of labelling (digital labelling).
Filed in Czech · English published by the European Commission
· · filed 10 Mar 2023 · source
Increasing the font size on labels will only make thing more complex for export as there will be less room for multiple languages. Printing quality is much better on modern printers and even smaller font sizes is much more readable. All this will succeed in doing is creating more waste and potentially less export for EU businesses.
Stellungnahme des Deutschen Verbandes Flüssiggas zur Überarbeitung der EU-Rechtsvorschriften zur Einstufung, Kennzeichnung und Verpackung von Chemikalien Der Deutsche Verband Flüssiggas e.V. begrüßt die Möglichkeit zur Überarbeitung der CLPVerordnung Stellung zu beziehen. Flüssiggas (LPG) bezeichnet unter Druck verflüssigte Mischungen aus Propan und Butan sowie in geringen Maßen deren entsprechenden Alkenen.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Improving the legibility of labels is in principle to be welcomed. The increasing overloading of labels with more or less useful information has inevitably led to ever smaller font sizes, making it difficult to read.
Filed in German · English published by the European Commission
· · filed 8 Mar 2023 · source
The impact on increasing font sizes is significant here. The increase in font size will discourage the use of multi-language labels and increase waste, labels will need to be removed and binned and re-printed for export to other countries.
· · filed 1 Mar 2023 · source
Input to EU Commission CLP proposal Feedback concerning minimum dimensions of labels, pictograms, and font size (Annex I, Table 1.3) The minimum requirements for label, pictogram, and font size are creating a potential string of issues: 1. CLP hazard labels in the EU are generally created in multiple languages by industry producers to simplify shipment of product to multiple countries in Europe.
· · filed 27 Feb 2023 · source
The proposed definition of a multi-component substance refers to identified impurities and additives, which contradicts the definition of a substance in the REACH Regulation and Regulation 1107/2009. Best practices can be found in ECHA’s ‘Recommendations for identification and naming of substances under REACH and CLP’, which refer to single-component, multi-component and UVCB substances.
Filed in Lithuanian · English published by the European Commission
· · filed 14 Feb 2023 · source
We appreciate the revision of hazard classification and implementation of new hazard categories. However, if harmonisation with other EU regulations is planned, please bear in mind that not all aspects are directly transferable.
· · filed 14 Feb 2023 · source
Regarding (11) Fold-out labels: We endorse the proposal to allow the use of fold-out labels in order to become more flexible in terms of multiple languages. However, the conditions for the allowance of a fold-out label has to be clear cut.
Hubergroup would like to comment on to the proposed revision of the CLP Regulation, and the documents published on 19th December 2022: Minimum Requirements for Labels (OLP text p43. Annex I para (2)) We are very concerned that labels are increasingly difficult to read as a result of additional information requirements (often due to substance reclassifications).
· · filed 3 Feb 2023 · source
We have two major concerns with the planned revision to the CLP regulation; text formatting on the labels and advertisement. First, we would like to express our concern about the intended increase of the minimum font size of hazard text on labels, especially for the packaging size of 3 to 50 L.
The changes proposed for the font size and letter spacing of hazard information will be detrimental to products sold with multi-lingual labels (particularly for countries such as Belgium where multi-lingual labels are a requirement) and products where large amounts of information are required under other regulations, such as the Biocidal Products Regulation.
· · filed 31 Jan 2023 · source
Good staff, I am writing in Italian to avoid misunderstandings due to my bad English regarding the draft published by the European Commission on the revision of CLP Regulation, Brussels, 19.12.2022 COM (2022) 748 final 2022/0432 (COD). I am Maurizio Ronchi, a chemical in Gammacolor, a small SME that imports and markets colorants for the textile/fashion sector.
Filed in Italian · English published by the European Commission
· · filed 30 Jan 2023 · source
See on the European Commission’s TRIS website the French draft decree listing products for which bulk sales are prohibited for public health reasons, which refers to classified chemicals and detergents, some of which will be banned from bulk sales in France. https://ec.europa.eu/growth/tools-databases/tris/fr/search/?trisaction=search.detail&year=2022&num=818
Filed in French · English published by the European Commission
With regard to the revision to the CLP Regulation, and the documents published on 19th December 2022, CEPE would like to share the following initial comments from our members on three important topics: Minimum Requirements for Labels (OLP text p43.
Feedback about article 18(3)(b) CLP not updated for considering new ED HH hazard. Neither the DA nor the OLP have updated the Article 18(3) (b) of CLP about the identity of substances in the mixture that contribute to the major health hazards (i.e. the substances to be reported on the mixture label as contains).
· · filed 20 Jan 2023 · source
Vewin, the association of water companies in the Netherlands strongly supports the introduction of new hazard classes in the Classification, Labelling and Packaging (CLP) proposal for a regulation 2022/0432. These new classes are an essential step in a connected effort of improved and modernized European regulations to protect sources of drinking water by restricting the use and emissions of hazardous chemical…
· · filed 15 Jan 2023 · source
We welcome the revision of the EU-CLP Regulation, but point out that it should not lead to an additional burden in terms of reporting obligations for economic operators. The Echa database already provides some valuable indications and the system of poison centres is sufficiently implemented.
Filed in German · English published by the European Commission
· · filed 21 Dec 2022 · source
The ERM Coalition strongly supports the inclusion of PMT (persistent, mobile, toxic) and vPvM (very persistent, very mobile) substances as new hazard classes in the CLP Regulation to fully address persistency, mobility and toxicity. This is an overdue milestone to also protect human health and drinking water supply. PMT/vPvM substances must not enter drinking water resources.
EurEau welcomes the introduction of new hazard classes in the Classification, Labelling and Packaging (CLP) proposal for a regulation 2022/0432. The classification of substances according to these classes in the CLP regulation is essential to further restrict the use of hazardous chemical substances via REACH.
EurEau welcomes the introduction of new hazard classes in the Classification, Labelling and Packaging (CLP) proposal for a regulation 2022/0432. The classification of substances according to these classes in the CLP regulation is essential to further restrict the use of hazardous chemical substances via REACH.
· · filed 1 Jun 2021 · source
Green Transition Denmark (GTD) welcomes the opportunity to provide feedback on the Commission’s discussions of the revision of EU’s CLP Regulation. GTD is a Danish NGO working to promote a green and sustainable transition of society. CLP is an essential tool to regulate hazardous chemicals. However, it needs to be updated to sufficiently support the implementation of the new Chemicals Strategy of Sustainability.
Cruelty Free Europe believes that the revision of the CLP Regulation in parallel with the Revision of REACH is an opportunity to bring animal testing to an end and move towards a modern EU regulatory system for chemicals based solely on non-animal methods. This would ensure better and more reliable information on chemicals for human health and the environment while ending cruel animal testing.
· · filed 1 Jun 2021 · source
On behalf of Confcommercio - Imprese per l'Italia, please find below the contribution to the Commission's roadmap for the future revision of the CLP Regulation. Require importers and downstream users to submit information on substances classified for physical effects or health hazards to poison centers and clarify obligations for distributors to submit such information, through an only representative or other means.
EFEO response to the Inception Impact Assessments on the revision of CLP regulation The European Federation of Essential Oils (EFEO) supports the objectives of the Chemicals Strategy for Sustainability (CSS) and welcomes the opportunity to comment on the Inception Impact Assessments (IIA) on the revision of the CLP regulation.
Directorate-General for Environment Department of Product Policy and Chemical Substances Risk Management Unit – Chemicals Competent Authority (REACH – CLP – PIC – POP – MINAMATA) CLP BELGIAN COMPETENT AUTHORITY - CONTRIBUTION SUBJECT Contribution to the Inception Impact Assessment on the revision of CLP regulation 01/06/2021 The CLP Belgian competent authority has remarks on the part B of the document on the bullet…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Brussels, 01 June 2021 European Chemical Employers Group’s (ECEG) response to the CLP inception impact assessment (IIA) ECEG welcomes the opportunity to comment on the European Commission’s proposals presented in the CLP IIA document. Below we highlight three points that are of outmost importance for our membership1. 1.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 1 Jun 2021 · source
Suomen luonnonsuojeluliitto (The Finnish Association for Nature Conservation) is the oldest and biggest environmental NGO in Finland. 1) EU legislation on packaging The limits for dangerous wastes in the EU REACH packaging regulations are extremely high.
· · filed 1 Jun 2021 · source
The European Society of Endocrinology (ESE), on behalf of more than 20,000 endocrinologists in Europe as well as the millions of patients with endocrine diseases whom it represents, welcomes the ambitious agenda of the European Commission (EC) to address the impact of Endocrine Disrupting Chemicals (EDCs).
· · filed 1 Jun 2021 · source
CROCPA welcomes the opportunity to provide feedback and makes the following comments: We believe that any new hazard class should be first implemented at UN level. We are concerned that the additional hazard classes and pictograms would increase label complexity and could compromise hazard communication.
Contact person: [name removed] [name removed] uploaded on the EU Commission website Have Your Say Oslo, 01/06/2021 Norwegian comments on the Inception impact assessment for revision of EU legislation on classification, labelling and packaging of substances and mixtures (CLP) We thank the Commission for this Inception Impact Assessment on the revision on CLP and the possibility to provide views on this.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 1 Jun 2021 · source
As an environmental scientist I support the goal in the Chemicals Strategy for Sustainability to propose new hazard classes and criteria in the CLP regulation. Persistence and mobility should be included as novel hazard classes. Further data availability should be improved to check the compliance and effectiveness of the regulation.
Humane Society International (HSI) welcomes this opportunity to comment on the Inception Impact Assessment – Revision of EU legislation on hazard classification, labelling and packaging of chemicals. By ensuring that the EU regulatory approach for chemicals is based on up-to-date science, the EU can contribute actively to reductions in animal use through a robust implementation of Directive 2010/63/EU – but it is…
· · filed 1 Jun 2021 · source
The Spanish Ministry for Ecological Transition and Demographic Challenge welcomes the Commission´s initiative to revise the two main chemical´s regulation in Europe. The European Union must be a global example of sound chemicals management. The sale of chemicals is estimated to double by 2030, making the proper management of chemicals key to achieving the Sustainable Development Goals.
Eurometaux thanks the Commission for the opportunity to comment on the CLP IIA. Please find attached our comments. Please do not hesitate to come back to us if you have any question. Eurometaux is willing to engage in the process to ensure CLP delivers its full potential.
The Child Rights International Network (CRIN) welcomes the opportunity to provide feedback on the revision of the EU legislation on hazard classification, labelling and packaging of chemicals (CLP). As a children’s rights organisation, we push for the protection of children’s rights from the exposure to hazardous chemicals.
Endocrine disruptors (EDs): We supports a horizontal mechanism to identify EDs based on the WHO definition. However, CLP is designed to classify adverse effects, whereas EDs have an endocrine mode of action that is causally linked to an adverse effect. We are concerned about the potential for duplication with existing legislation.
Automotive Submission on the Revision of EU legislation on hazard classification, labelling and packaging of chemicals The Automotive Industry welcomes the opportunity to provide feedback on the inception impact assessment. Making the economy and society more sustainable.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The CLP Regulation has proven instrumental for the proper identification and communication of hazards of substances and mixtures placed on the market in the EU and thus to ensure a high level of protection of human health and the environment as well as an efficient functioning of the internal market.
· · filed 1 Jun 2021 · source
PRODAROM member of IFRA welcomes the opportunity to comment on the European Commission Inception Impact Assessment on CLP. Full comments are available in the IFRA response. Inclusion of new hazard classes should first take place under the UN Globally Harmonized System of Classification and Labelling of Chemicals framework.
The PETA Science Consortium International e.V. promotes robust non-animal testing methods that protect human health and the environment. We welcome the opportunity to comment on the consultation ‘Revision of EU legislation on hazard classification, labelling and packaging of chemicals‘. Please find our response attached.
2021.06.01 FNADE’s feedback on revision of CLP regulation FNADE, the French private companies waste management and environmental services association, very welcomes the revision of the CLP regulation to help achieve a toxic-free environment.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The European steel industry, represented by EUROFER, welcomes the European Commission’s Inception Impact Assessment for the revision of EU legislation on Hazard Classification, Labelling and Packaging of Chemicals, which aims to improve this legislation. We appreciate the possibility for the industry to comment on this topic and take this opportunity for providing our contribution in the attached file.
Although CLP has proven to be a harmonized way of identifying and communicating hazards and an effective tool to ensure the safe use of chemicals, the Commission has deemed it necessary to review it. The Spanish National Association of Fertilizer Manufacturers (ANFFE) would like to transmit to the European Commission its observations on the revision of the CLP Regulation, that are included in the attached document.
Jernkontoret, the Swedish Steel Producer's Association, welcomes the European Commissions's IIA on CLP revision as a part of the Chemical Strategy for Sustainability and the opportunity to improve this legislation. Jernkontoret wants to comment the IIA revision on CLP as part of the ongoing open consultation.
The CLP Regulation is an essential tool to identify, communicate and trigger the regulation of hazardous chemicals in Europe. However, CLP needs to be improved to support the implementation and the level of ambition of the Chemicals Strategy of Sustainability (CSS).
Unilever is committed to making sustainable living commonplace and therefore we welcome the Commission’s initiative to review the CLP Regulation as part of the EU Green Deal (EGD) and the EU Chemicals Strategy for Sustainability (CSS).
EuroCommerce is the principal European organisation representing the retail and wholesale sector. It embraces national associations in 31 countries and 5.4 million companies, both leading global players and many small businesses. Retail and wholesale provide a link between producers and 500 million European consumers over a billion times a day.
In the National Fertiliser Manufacturers Association (ANFFE) we consider that REACH is fit for purpose and meets its objectives. However, we understand that there are areas where improvements can be made, including the following: • simplification of procedures for the authorisation, registration and evaluation of substances, • coherence between REACH and other legislation, • proportionate approach to the…
Filed in Spanish · English published by the European Commission
· · filed 1 Jun 2021 · source
We welcome both the opportunity to comment on the Roadmap and the progress the Commission has made in the much-needed reform of CLP, the keystone of the generic risk approach in EU law. B. Problem the initiative aims to tackle We agree with the problems identified, but regret that the current, serious issues with self-identification are not explicitly mentioned or highlighted.
PU Europe, the European Federation of PUR/PIR rigid polyurethane insulation manufacturers, appreciates the opportunity to contribute to the inception impact assessment for the revision of the CLP Regulation. PU Europe supports the objectives of the Chemicals Strategy for Sustainability (CSS) aiming at achieving a higher level of protection of citizens and the environment against hazardous chemicals and encouraging…
Eurima supports the once-in-a-decade exercise by the European Commission to revise and update the CLP Regulation. Our sector represents European Mineral Wool Insulation Manufacturers. The mineral wool fibres manufactured by our members are registered under REACH as bio-soluble. Mineral wool fibres manufactured today are exempted under the Note Q to Annex VI to the CLP Regulation.
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Section A. The problem formulation is incomplete with respect to the following aspects: - All legislation pertaining to chemical safety needs frequent adaptation to scientific and technical progress. The CLP Regulation translates the UN GHS into European Law, therefore the standard procedure for major updates is by first introducing such changes under the GHS and then subsequently adapting the CLP Regulation…
1. Compliance deadlines in ATPs should be rethought to avoid waste and remove burdens. Today, compliance deadlines in ATPs are sell through dates, meaning that 18 months after the entry into force of the ATP, it is no longer possible to make the product available to customers. This approach is raising a great deal of problems (see full list below) particularly the waste it generates (both substances and mixtures).
Automotive suppliers’ submission on the Revision of the EU legislation on hazard classification, labelling and packaging of chemicals The Automotive Industry welcomes the opportunity to provide feedback on the inception impact assessment. Making the economy and society more sustainable.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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To whom it may concern, CLP (Regulation (EC) No 1272/2008) provides the foundation for high level of protection of human health and the environment as well as the free movement of substances, mixtures and articles. The classification and labelling requirements inform European workers and the public of hazardous properties.
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We observe an increasing number of difficulties related to the CLH process. In particular, when a hazard classification has an immediate impact on the risk management under another legislation, regularly socio-economic impacts or feasibility assessments were not performed. In many cases the impact was significant and often unwanted in relation to other policy objectives.
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The Danish Consumer Council Think works, inter alia, to ensure that consumers are not exposed to harmful or undesirable chemistry. The Danish Consumer Council Think supports the ambitious EU Chemicals Strategy (CS) and considers that all its objectives must be met. The Danish Consumer Council Think supports the introduction of new hazard classes, e.g.
Filed in Danish · English published by the European Commission
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Comments from the Irish Health and Safety Authority on the Chemical Strategy CLP Inception Impact Assessment (IIA) The Health and Safety Authority is a Competent Authority (CA) for the CLP Regulation in Ireland and would like to make the following comments on the IIA: We welcome and support proposals to examine hazard classes and criteria with a view to introducing additional new hazard classes.
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MedTech Europe welcomes the opportunity to provide feedback on the upcoming revision of Regulation (EC) No 1272/2008 on hazard classification, labelling and packaging of chemicals (the CLP Regulation). We look forward to continuing engaging in this initiative and other policy initiatives within the Chemicals Strategy for Sustainability.
COSMED welcomes the opportunity to provide its feedback on the intended revision of the REACH Regulation. Please find our full contribution in attachment. COSMED is the French cosmetic association for SMEs, a non-profit seeking association with more than 920 members, in France and Europe
PlasticsEurope and its members, welcome the opportunity to contribute to the European Commission's inception impact assessment on revision of the CLP Regulation. Via the attached document, feedback is provided on the problems this initiative aims to tackle. About PlasticsEurope: PlasticsEurope is the pan-European association of plastics manufacturers.
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Technology Industries of Finland’s comments on the Inception Impact Assessment of the revision of REACH and CLP regulations The Finnish Technology Industries promotes competitiveness and operational preconditions of technology industry companies, the largest and most important export sector in Finland.
While medicines are exempted from REACH, bans and restrictions on substances used in manufacturing can be prohibitive for the production of certain medicines or diagnostics as often no suitable alternatives are available.
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FEFANA welcomes the opportunity to offer feedback on the Revision of EU legislation on hazard classification, labelling and packaging of chemicals. FEFANA appreciates that, for the implementation of the Green Deal, the chemicals strategy for sustainability sets out a number of ambitious actions.
Inception impact assessment related to the revision of CLP Regulation – ANSES comments The following remarks on the European Commission document on inception impact assessment related to revision of EU legislation on hazard classification, labelling and packaging of chemicals are provided by ANSES (French Agency for food, environmental and occupational health safety).
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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Drinking Water Company Oasen (The Netherlands) strongly support the ambition in the Chemicals Strategy for Sustainability to "propose new hazard classes and criteria in the CLP Regulation to fully address environmental toxicity, persistency, mobility and bioaccumulation", by inclusion of PMT and vPvM as new hazard classes
Addressing the CLP revision roadmap, the Polish Union of the Cosmetics Industry would like to highlight the following issues: New hazard classes The Union considers the CLP Regulation as an effective tool for harmonised hazard identification and classification at substance level. The regulatory consequences of CLP classifications, i.e.
Mengend Nederland supports the objectives of the CSS to achieve a higher level of protection of citizens and the environment against hazardous chemicals. Amendments to the CLP Regulation in this regard should focus on risks above hazards, enable suppliers of chemicals to develop safer al-ternatives and provide downstream users with enough time to reformulate their products to achieve the same performance.
SEMI Europe welcomes the opportunity to provide its feedback on the intended revision of the CLP Regulation. The CLP revision policy options appear to be well aligned with the overall concerns identified in the Inception Impact Assessment. However, the proposal to include additional hazard information on labels for products currently outside the scope of the CLP Regulation requires careful consideration.
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SNIAA contribution to the public consultation on the Revision of the CLP Regulation 1er juin 2021 SNIAA (French Flavour Association) is a member of EFFA (European Flavour Association), the voice of the flavour industry in Europe.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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30 years have passed since the concept of “endocrine disruptors” (EDCs) was developed at the Wingspread Congress on 26-28 July 1991. The Health Environment Network (RES), which initiated the ban on Bisphenol A in feeding bottles, has long advocated the establishment of horizontal criteria for EDCs chemicals.
Filed in French · English published by the European Commission
The European Solvent Recycler Gourp - ESRG - are supportive of the main aims of the proposals. In respect of the Circular Economy, ESRG would like to see updated Guidance offered to Member States in respect of managing standards for full recoveries derived from wastes and the use of exemptions to support both REACH and in turn CLP.
Eurogypsum, the association representing the interests of the European industry extracting and processing gypsum, welcomes the inception impact assessment on the revision of the EU legislation on hazard classification, labelling and packaging of chemicals (CLP Regulation).
Lubin, 31 May 2021 Revision of EU legislation on the CLP - KGHM POLSKA MIEDŹ S.A. COMMENTS ON THE INCEPTION IMPACT ASSESSMENT (IIA) KGHM Polska Miedź S.A. welcomes the possibility to comment on the CLP Inception Impact Assessment. A harmonised way of identifying and communicating hazards is crucial to ensure the safe use of chemicals at global, national and regional level.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
ChemSec welcomes the proposed changes and additions to the CLP regulation, as laid out in the Chemicals Strategy. We fully support the aim to urgently achieve a better protection of human health and the environment through more efficient identification, labelling and communication on hazardous chemicals.
The Health and Environment Alliance (HEAL) welcomes the opportunity to comment on the inception impact assessment for the revision of the EU legislation on hazard classification, labelling and packaging of chemicals (CLP).
FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe welcomes the Revision of EU legislation on hazard classification, labelling and packaging of chemicals which aims at protecting people and the environment better against hazardous chemicals and at encouraging innovation for the development of safer alternatives.
Plastics Recyclers Europe (PRE) welcomes the opportunity to give a feedback to the Inception Impact assessment on the Revision of EU legislation on hazard classification, labelling and packaging of chemicals. As an industry association representing plastic recyclers, we are supportive to update the CLP Regulation given more than a decade of scientific and technological progress.
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The CLP Regulation needs to be improved and further developed to achieve the goals of the Chemicals Strategy (CS), as correctly observed in the Inception Impact Assessment (IIA). BEUC welcomes the Commission’s initial proposals in this regard.
In the past years the Slovenian chemicals industry was able to implement the CLP-criteria very well. For our industry, which is primarly SME-structured, it was, however, a significant effort to do so. In this respect we are not supportive of the proposed deviations from the international GHS-rules. Important trade-partners of our industry are outside the EU, so a coherence with the UN-GHS is highly important for us.
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CropLife Europe (CLE) welcomes the opportunity to provide feedback and makes the following comments: - New Hazard Classes Europe has been a leading player in the development of the GHS, bringing numerous benefits in terms of international harmonisation of safety standards and facilitation of trade. The Commission’s plan sends a clear message that the EU no longer believes in international cooperation.
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The CLP regulation is important not only because it allows all European workers and consumers to be informed through the same labelling about the intrinsic properties of hazardous chemicals but also because it automatically brings these hazardous substances within the scope of around 20 pieces of European Legislation controlling their use.
Classification is a key challenge of the interface between waste, chemicals and products. It is one of the main tools that will pave the way to the EU Green Deal objective of a zero pollution ambition for a non-toxic environment.
Filed in French · English published by the European Commission
To: The European Commission Inception Impact Assessment for the revision of EU legislation on hazard classification, labelling and packaging of chemicals – comments from the Competent Authority of Denmark The Danish Government would like to thank the Commission for the opportunity to comment on the Inception Impact Assessment for the revision of the EU legislation on hazard classification, labelling and packaging of…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
EU Transparency Register number: 60974102057-03 31 May 2021 France Industrie input on CLP Revision Roadmap France Industrie welcomes the opportunity to comment on European Commission inception impact assessment on CLP. We want to emphasise that the UN GHS (Globally harmonised System of Classification and Labelling of Chemicals) is a key contributor to global harmonisation of chemicals legislations.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Revision of EU legislation on hazard classification, labelling and packaging of chemicals - Inception impact assessment – feedback from the Czech Chamber of Commerce The Czech Chamber of Commerce welcomes the opportunity to provide first comments on the CLP Revision Inception Impact Assessment.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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Main objectives: Speeding up harmonized classification and clarifying the obligations to classify mixtures. No additional burdens. Substances/mixtures falling under other regulations are subject to more restrictive assessments -> additional label/warning statements would be contradicting and irritating. GHS as decisive. Feralco supports the Feedback by Cefic as well.
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For references please see the attached document. A. Context and Problem The Endocrine Society welcomes the proposal to revise the European Union (EU) legislation on Classification, Labeling and Packaging of chemicals (CLP) to align legislation with the objectives described in the Chemicals Strategy for Sustainability (CSS).
The Japan Chemical Industry Association (JCIA) welcomes the feedback opportunity regarding Inception Impact Assessment/Revision of CLP. The JCIA supports the noble ambitions of the EU’s Chemicals Strategy for Sustainability (CSS) which aims to improve the EU chemicals policy, including REACH and CLP, for sustainability and competitiveness.
DI welcomes the possibility to submit our feedback on the CLP revision Inception Impact Assessment consultation. In general, DI - supports the goals in the Chemicals Strategy for Sustainability and to build on the chemicals safety legislation to ensure safe and sustainable use of chemicals - recognizes the need to find a way to address new hazards as endocrine disrupting effects - strongly support the harmonization…
Submitted Electronically May 31, 2021 Re: ACC comments on the CLP Inception Impact Assessment To Whom It May Concern: On behalf of the American Chemistry Council (ACC)1 and our member companies, I am writing to share our comments regarding the Inception Impact Assessment titled “Revision of EU legislation on hazard classification, labelling and packaging of chemicals” that was published earlier this month.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The European Flavour Association (EFFA) supports the objectives of the Chemicals Strategy for Sustainability (CSS) aiming at achieving a higher level of protection of citizens and the environment against hazardous chemicals and encouraging innovation for the development of safe and sustainable alternatives.
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The NORMAN network (www.norman-network.net) is an independent, non-profit, multidisciplinary and multinational organisation in the field of contaminants of emerging concern, which brings together more than 80 organisations in Europe and beyond, representing various stakeholders such as competent authorities, reference laboratories established at the national level, research centres, academia and industry.
Women Engage for a Common Future, WECF, welcomes the European Commission’s plan to revise the CLP Regulation. As an international ecofeminist network of 150 women and civil organizations NGOs committed to build a healthy environment and be active at EU level for moving towards a toxic-free future, Women Engage for a Common Future (WECF) calls the EU authorities to stronger regulations in context of harmful…
Japan Business Council in Europe (JBCE) welcomes the feedback opportunity regarding Inception Impact Assessment/Revision of CLP. JBCE supports the EU’s aims at ensuring both a well-functioning single market for chemicals and a high level of protection of human health and of the environment.
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FEIQUE appreciates the opportunity to contribute to the CLP inception impact assessment. A harmonised way of identifying and communicating hazards at national, regional and global level is essential for industry to ensure the safe use of chemicals. We then moved on to highlight some points of the proposals, and an accompanying document dealing with all of them.
Filed in Spanish · English published by the European Commission
Henkel welcomes the Commission’s commitment to ensure that the regulatory framework for chemicals reflects the objective to better combine health and environmental protection with increased global competitiveness and a strengthened internal market. However, an open discussion based on a holistic understanding of potential impacts on how this can be best achieved is needed before proposing legislative changes.
The Test & Measurement (T&M) Coalition was created in 2005 and represents an ad-hoc group of companies active in producing T&M industrial type products. The Coalition members are leading companies in the sector including Agilent Technologies, Fluke Corporation, Keithley Instruments, Keysight Technologies, National Instruments, Tektronix and Thermo Fisher Scientific.
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The Test & Measurement (T&M) Coalition was created in 2005 and represents an ad-hoc group of companies active in producing T&M industrial type products. The Coalition members are leading companies in the sector including Agilent Technologies, Fluke Corporation, Keithley Instruments, Keysight Technologies, National Instruments, Tektronix and Thermo Fisher Scientific.
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Cosmetics Europe is the trade association representing cosmetic and personal care product manufacturers in Europe. We recognise that safe use of chemicals requires as a first step the identification and communication of hazards. This should be done in a predictable and internationally compatible way at national, regional and global level, in line with the international GHS system to minimize divergence.
Eurocolour’s input to the inception impact assessment of the Revision of EU legislation on hazard classification, labelling and packaging of chemicals The EU’s CLP Regulation in combination with the REACH Regulation are unique in such a form and extent worldwide.
VdMi’s input to the inception impact assessment of the Revision of EU legislation on hazard classification, labelling and packaging of chemicals The EU’s CLP Regulation in combination with the REACH Regulation are unique in such a form and extent worldwide.
CHEM Trust would like to take this opportunity to comment on the Commission’s plans for revising the EU CLP legislation. CHEM Trust welcomed the commitments made in the Chemicals Strategy for Sustainability (CSS) for strengthening the identification and control of chemicals with properties that are endangering public health and the environment.
ETRMA views on the Inception Impact Assessment on the revision of CLP Brussels, 31st of May 2021 Rubber is a versatile material flexible and resistant used for many applications. The majority of the industry producing from rubber articles in Europe is organized in two main blocks. The most visible and known is Tyres present in vehicles.
The Microbial Control Executive Council (MCEC) welcomes the opportunity provided by the European Commission to submit views about the forthcoming revision of EU legislation on hazard classification, labelling and packaging of chemicals (CLP, (EC) No 1272/2008).
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Chemical Industry Federation Finland appreciates the opportunity to comment the Inception impact assessment document. This consultation is very valuable, as proper impact assessment is the basis for any good regulatory process. We support the comments made by Cefic and would like to emphasize the following: The Chemical Strategy for sustainability proposes multiple changes to REACh and CLP regulations.
FEFAC welcomes the opportunity to comment on the directions envisaged by the EU Commission for a revision of the EU legislation on hazard classification, labelling and pakaging, in particular as regards the establishment of new hazard classes. The strength of the EU legislation on Classification, Labelling and Packaging of chemicals lays in its alignment with the UN GHS process.
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ALPLA is one of the leading companies involved in plastic packaging. Around 21,600 employees worldwide produce custom-made packaging systems, bottles, caps and moulded parts at 178 sites across 45 countries. Hazard classification and labelling are very important measures for industries to communicate its hazard to end-users.
Cefic welcomes the opportunity to comment on European Commission inception impact assessment on CLP. The text below highlights the key points related to five proposed options but detailed comments on all can be found in the attached document. 1.
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The European Melamine Producers Association (EMPA) welcomes the opportunity provided by the European Commission to comment on the revision of the CLP Regulation, expected for Q2 2022. The publication of the Chemicals Strategy for Sustainability marked a milestone in the European chemicals policy framework, including the proposal to revise the CLP Regulation.
Ambitious policy goals must be supported by robust legislation and a sound process to enable the transition. A.I.S.E. urges the Commission not to rush decision-making processes in order to meet unrealistic deadlines set in the CSS. The impact of all changes must also be robustly assessed, in conjunction with all relevant stakeholders. A.I.S.E. welcomes measures that will minimise administrative burden.
With the objective of implementing new hazard class within CLP regulation, each chemical should be documented on the its capacity to elicit an endocrine activity. Taking into account the number of chemicals to address, implementing new tools is needed. The lack of existing data in the literature should systematically lead to the requirement to generate new data.
EPMF Position Paper 31 May 2021 Inception Impact Assessment – Revision of the EU legislation on hazard classification, labelling and packaging of chemicals The European Precious Metals Federation (EPMF) supports the ambition of the European Green Deal and the objectives of the Chemicals Strategy for Sustainability. To achieve them, a targeted revision of the CLP Regulation was launched.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
essenscia welcomes the opportunity to comment on European commission inception assessment on CLP. Safe use of chemicals both for human health and the environment requires the identification and communication of hazards at national, regional and global level in a clear and consistent way, without duplication or contradictions. essenscia and its members support the comments submitted by Cefic.
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Comment BAuA (Division Fb4, Division FB5) Ref. Ares(2021)2969734 - 04/05/2021 Section B "Objectives and Policy options”: We support the COM’s initiative to examine, clarify and improve the labelling rules considering mul-tilingual fold-out labels and tailored solutions for cases when there is not enough space on packag-ing.
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IndustriAll European Trade Union is a federation of independent and democratic trade unions representing manual and non-manual workers in the metal, chemical, energy, mining, textile, clothing and footwear sectors and related industries and activities. We speak for 7 million working men and women united within 180 national trade union affiliates in 38 European countries.
The International Fragrance Association welcomes the opportunity to comment on the European Commission Inception Impact Assessment on CLP. Full comments are available in the attachment. Inclusion of new hazard classes should first take place under the UN Globally Harmonized System of Classification and Labelling of Chemicals framework.
EurEau is the European association of water service providers with 34 national member organisations in 29 countries. ~ The zero-pollution ambition from the European Green Deal delivered the Chemicals Strategy for Sustainability. One of its objectives is to better protect the environment against hazardous chemicals.
DUCC urges the European Commission not to rush decision-making processes for CLP (or any other legislation) in order to meet unrealistic deadlines, set in the CSS, but to ensure that these are conducted properly in line with the principles of Better Regulation.
We welcome the possibility to provide input to the Inception Impact Assessment on the revision of the CLP Regulation. As the EU Commission states in the introduction to the Inception Impact Assessment for the revision of the CLP Regulation “the CLP Regulation is the core piece of Union legislation for the hazard assessment of chemicals, stemming from the United Nations’ global standard (GHS), and sets out the hazard…
• ÖVGW is the Austrian Association for Gas and Water, representing more than 250 water suppliers, supplying more than 70% of Austria’s population. • ÖVGW welcomes the zero-pollution action plan as part of the European Green Deal together with the Chemicals Strategy for Sustainability for a toxic free environment with the aim to better protect the environment – and drinking water resources - against hazardous…
Roadmap CPL — Observations Open public consultation EU Commission It is important that the CLP Regulation is clear and transparent in terms of risk identification, classification and responsibilities of different actors. It is important to extend the area where CLP applies if necessary to reduce risks to human health and the environment. It is not wrong to open up before a completely new group, e.g.
Filed in Swedish · English published by the European Commission
BV Glas supports the goal of the Commission to achieve a higher level of protection of citizens and of the environment against hazardous chemicals and believes that its products are aligned with these criteria. However, the actions foreseen by the European Commission seem to pose a lot of new requirements on companies. These requirements will lead to enormous costs and efforts for companies.
The German Paint and Printing Inks Industry Association (VdL) is grateful for the opportunity to comment on the planned measures as part of this consultation.Our industry depends on a broad raw material portfolio to ensure the effectiveness of the various products of the coatings and printing industries and will be bound by the plateed measures. Please find attached our comments.
Filed in German · English published by the European Commission
Memorandum Ref. Ares(2021)3571203 - 31/05/2021 31 May 2021 M2021/ Ministry of the Environment Swedish comments on the Inception impact assessment for revision of EU legislation on classification, labeling and packaging of substances and mixtures (CLP) The Swedish Government welcomes the opportunity to comment on the upcoming review on the CLP Regulation.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Federchimica believes that in order to achieve global harmonisation, the EU should avoid introducing regional specificities and implementing classifications above and beyond those not covered by the GHS. The announced intention would lead to an inconsistency between EU and non-EU legislations and may cause global market divergences.
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EFPIA, the research-based pharmaceutical industry is supportive of the European Commission initiatives related implementation of the Green Deal, specifically the chemicals strategy for sustainability, which sets out a number of actions that require a targeted revision of the Regulation on the classification, labelling and packaging of chemical substances and mixtures.
Biopharmachem Ireland supports the Commission’s objective to revise, to improve and to simplify the CLP regulation. CLP should not unilaterally diverge from the UN GHS for classification of chemicals as this will put EU based legal entities at a competitive disadvantage.
On behalf of the Biogeochemistry and Ecotoxicology unit, we believe that high persistence alone is a major cause of concern and a sufficient basis for regulation of a chemical. As such, we strongly support the ambition in the Chemicals Strategy for Sustainability to "propose new hazard classes and criteria in the CLP Regulation to fully address environmental toxicity, persistency, mobility and bioaccumulation", by…
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CIHEF represents the French Essential oil sector of lavandin, lavender and clary sage. Its members are plant growers/farmers of lavandin, lavender and clary sage plants, distilleries, and cooperatives of essential oils as well as companies, which buy essential oils directly to a farmer or a cooperative. Its members are mainly micro and small enterprises (SMEs).
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• We strongly support the ambition in the Chemicals Strategy for Sustainability to "propose new hazard classes and criteria in the CLP Regulation to fully address environmental toxicity, persistency, mobility and bioaccumulation", by inclusion of PMT and vPvM as new hazard classes; Link…
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We would like to express our support concerning the items in the position papers of the “German chemical industry association - Verband der Chemischen Industrie (VCI)” and “Cefic, the European Chemical Industry Council”. Additionally, in our opinion CLP must be equipped to deal with hazards resulting from the physical state.
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The revision of Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures (CPL Regulation) is adapted to scientific and technical progress. It aims to improve the identification and classification of hazards and to improve the provision of information on the occurrence of health hazards in the handling of chemicals.
Filed in German · English published by the European Commission
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In general, SK CA welcome the proposed revision of CLP and believe it is one of the very important actions of Chemicals Strategy for Sustainability: Towards a Toxic-free Environment. In this comment, we are providing our view on the issues we consider the most problematic.
Fecc acknowledges the inception impact assessment on CLP under the objectives of the Chemical Strategy for Sustainability (CSS). In this context we would like to raise the following points on behalf of the European chemical distribution sector, above all on behalf of the many SMEs we represent: 1.
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Generations Futures welcomes the launch of this initiative on the revision of the CLP Regulation and its inclusion in the framework of the “Chemicals Sustainability Strategy — Towards a Toxic Free Environment”, adopted by the Commission on 14 October 2020.
Filed in French · English published by the European Commission
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We strongly support the ambition in the Chemicals Strategy for Sustainability to "propose new hazard classes and criteria in the CLP Regulation to fully address environmental toxicity, persistency, mobility and bioaccumulation", by inclusion of PMT and vPvM as new hazard classes.
Brussels, 31 May 2021 Position Paper on the Revision of the CLP Regulation BeST The Beryllium Science and Technology Association (BeST) represents the suppliers of beryllium metal and beryllium containing alloys in the EU market and has the objective of promoting sound policies, regulations, science and actions related to the safe use of beryllium and to serve as an expert resource for the international community on…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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The Polish Association of the Cosmetics and Detergent Industry (PSPKD) supports the political commitments made in the framework of the CSS to enhance the protection of health and the environment. However, decision-making processes for the review of the CLP should not be speeded up, but should be dealt with properly, in line with the Better Regulation principles.
Filed in Polish · English published by the European Commission
VCH Opinion on Revision of EU legislation on hazard classification, labelling and packaging of chemicals The Chemiehandel Association would like to thank the European Commission for the opportunity to comment. Our opinion is attached as a PDF file. The VCH thanks the EU Commission for the openness to provide feedback. Please find our feedback as per pdf file attached.
Filed in German · English published by the European Commission
Marcallo con Casone, 28 maggio 2021 Siamo invisibili. Ma siamo ovunque! 1. The purpose of the GHS is to harmonize the classification and labeling criteria of goods in order to ensure a homogeneous circulation of information.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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We strongly support the ambition in the Chemicals Strategy for Sustainability to "propose new hazard classes and criteria in the CLP Regulation to fully address environmental toxicity, persistency, mobility and bioaccumulation", by inclusion of PMT and vPvM as new hazard classes;
CLP Regulation is first of all the implementation of the GHS. Therefore, it is very important for CLP to strictly follow the GHS. Adding new hazards category is helpful only if those are included in GHS, in order to avoid confusion during circulation of chemicals across countries. Additional information is included in the eSDSs as requested for REACH regulation.
Comments from the Global PFAS Science Panel: We as scientists from different institutions from Europe and the US support the overall aim of the revision of the CLP legislation, as outlined in the Chemicals Strategy for Sustainability, and in particular the proposal to introduce the classifications PBT, vPvB, PMT, and vPvM into the CLP Regulation.
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An undiscussed issue is the widespread presence of substances with endocrine disrupting properties (endocrine disruptors or EDCs) in a wide variety of everyday objects, in the environment and in the body of women and men, including, and most alarming, in the developing body of embryos and boys and girls (this statement can be seen in a large number of studies and among them, those arising from the EU biomonitoring…
Filed in Spanish · English published by the European Commission
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In the name of the research groups involved in chemical risk assessment at the University of Antwerp (Belgium), we strongly support the ambition in the Chemicals Strategy for Sustainability to propose new hazard classes and criteria in the CLP Regulation.
FEICA, the Association of the European Adhesive & Sealant Industry, is a multinational association representing the European adhesive and sealant industry. Today's membership stands at 15 National Association Members, 24 Direct Company Members and 19 Affiliate Company Members. The European market for adhesives and sealants is currently worth more than 17 billion euros.
Our industry depends on a broad raw material portfolio to ensure the functionality of the diverse products of the coatings and printing inks industry and is therefore concerned about the proposed development, which may lead to the disappearence of key chemistries simply based on hazard and not on risk. Please find attached our comments.
The Revision of EU legislation on hazard classification, labelling and packaging of chemicals is crucial for the successful implementation of the Chemicals Strategy for Sustainability (CSS) and we therefore thank the European Commission for the opportunity to provide inputs to the roadmap consultation.
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The Center for International Environmental Law (CIEL) welcomes the opportunity to provide feedback on the revision of the EU legislation on hazard classification, labelling and packaging of chemicals (CLP). CIEL and its many partners in the EDC Free Coalition have been advocating for the establishment of horizontal criteria for endocrine-disrupting chemicals (EDCs) for many years.
Picon is a leading industry trade association representing manufacturers and suppliers to the Printing, Papermaking and Paper Converting sectors and welcomes the opportunity to respond to this Inception Impact Assessment (IIA) on the planned revision of Regulation (EC) No. 1272/2008 on the classification, labelling and packaging of substances and mixtures (CLP Regulation).
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28 May 2021 FEC Position on CLP Inception Impact Assessment FEC understands the need of introducing new hazard classes to increase protection of population, workers and environment, we believe however that these classes should be agreed at global level and should be coherent with the GHS classification.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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Revision of EU legislation on hazard classification, labelling and packaging of chemicals – Impact assessment Introduction of new hazard classes (such as endocrine disruptors) and corresponding criteria: The classification of waste is based on chemicals legislation but should remain separate to the CLP regulation as the outcomes for chemicals and waste are different.
FoodDrinkEurope position on the ‘Revision of EU legislation on hazard classification, labelling and packaging of chemicals’ Inception Impact Assessment FoodDrinkEurope is the organization representing Europe’s food and drink industry, composed of 294,000 businesses and 4.7 million workers and Europe’s largest manufacturing industry.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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As a Polish competent authority for REACH and CLP regulations, we are happy to share the following comments: - We support introducing additional new hazard classes for ED, PBT, vPvB, and PMT, vPvM. However, we believe that the inclusion of such new classes in CLP should be discussed first at the GHS level, to ensure that new criteria can be accepted globally.
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We strongly support the ambition in the Chemicals Strategy for Sustainability to "introduce endocrine disruptors, persistent, mobile and toxic and very persistent and very mobile substances as categories of substances of very high concern" within REACH.
· · filed 28 May 2021 · source
GHS creates an international level playing field for a growing number of countries, hereby contributing to the implementation of SAICM (Strategic Approach to International Chemicals Management), which is a key objective of the Commission’s global agenda reiterated in the CSS.
The European Federation for Construction Chemicals (EFCC) represents European construction chemicals companies and national member associations, representing raw materials producers and formulators of finished products, including SMEs, across the European Union. EFCC welcomes the opportunity to participate in the public consultation on the Inception Impact Assessment for CLP.
On 4 May 2021, the EU Commission published its Inception Impact Assessment regarding the proposed CLP Revision. This roadmap to be commented on in this context is part of the Chemicals Strategy for Sustainability. The CLP Regulation regulates the classification, labelling and packaging of chemicals and implements the internationally valid Globally Harmonised System (GHS) of the United Nations (UN) in the EU.
Impact assessment consultation on o Revision of EU legislation on hazard classification, labelling and packaging of chemicals. CLP o Revision of EU legislation on registration, evaluation, authorization and restriction of chemicals.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 27 May 2021 · source
In the framework of revision of the CLP Regulation the introduction of new hazard classes (such as endocrine disruptors) and corresponding criteria is proposed. The criteria for identification of endocrine disruptors (EDs) for the purposes of the Biocidal Products Regulation and the Plant Protection Products Regulation are in place.
· · filed 27 May 2021 · source
PL (Ministry of Economic Development, Labour and Technology) welcomes upcoming changes to the CLP regulation, and our main comment is not to rush decision-making processes. Any initiative shall be conducted with regards to the principles of Better Regulation, sound science and cooperation with relevant stakeholders.
· · filed 27 May 2021 · source
Another aspect, it is scandalous that those who export to the EU are allowed to fail to provide the least cooperation to those who care. I am referring to the NON-classifications that Asian manufacturers continue to maintain on their products. The Commission must, indeed already had to, ensure that the competent authorities of the EU and of the exporting countries of chemicals dialogue.
· · filed 27 May 2021 · source
the GHS exists as a global harmonized system, I don't understand why the EU with CLP would like to introduce other risk categories, disharmonizing a project that finally wants to unify the classifications. But why did the Commission stick to the "most ambitious chemicals regulation in the world", but are you aware of the damage you already do to industry and especially to SMEs?
· · filed 27 May 2021 · source
Motip Dupli thanks the EU Commission for this initiative and for opening this consultation. We support the following proposals of the Commission. Motip Dupli is a leading supplier of coating products in aerosols and 12 ml touch-ups. We market our products in total Europa. We produce a huge variety of colours serving the car repair market.
· · filed 27 May 2021 · source
PAN Europe welcomes the European Commission’s intent to upgrade the CLP Regulation. In view of its downstream consequences on different Regulations, including the PPPs Regulation 1107/2009, it is a key factor to significantly increase the level of protection of human health and the environment provided by the EU chemicals framework.
According to Wirtschaftsvereinigung Stahl, the CLP Regulation is an important instrument contributing to the implementation in the EU of the Globally Harmonised System of Classification and Labelling of Chemicals (GHS) initiated by the UN.
Filed in German · English published by the European Commission
· · filed 27 May 2021 · source
The DyStar Group, a leading dyestuff & chemical manufacturer and solution provider, offering customers across the globe a broad portfolio of colorants, specialty chemicals, and services, welcomes the opportunity to give feedback on the CLP revision inception impact assessment.
· · filed 26 May 2021 · source
Position on the initiative to revise the CLP-Regulation The European Green Deal and the Chemicals Strategy for Sustainability develop to be the umbrella for a number of euphonic proposals lacking a tedious consideration of the consequences. The vision presented to bloat the CLP-Regulation is one of them. Within two decades the European share of global chemical industry dropped from 30% to 15%.
On 4 May 2021, the EU Commission published its Inception Impact Assessment regarding the proposed CLP Revision. This roadmap to be commented on in this context is part of the Chemicals Strategy for Sustainability. The CLP Regulation regulates the classification, labelling and packaging of chemicals and implements the internationally valid Globally Harmonised System (GHS) of the United Nations (UN) in the EU.
Hubergroup, an European printing inks and chemicals manufacturer with a global presence, welcomes the opportunity to comments on the CLP revision inception impact assessment. We fundamentally agree on the main objectives included in the Chemicals strategy for sustainability (CSS), although we are concerned with the method of implementation and the speed of the action proposed.
· · filed 25 May 2021 · source
I strongly support the ambition in the Chemicals Strategy for Sustainability to "propose new hazard classes and criteria in the CLP Regulation to fully address environmental toxicity, persistency, mobility and bioaccumulation", by inclusion of PMT and vPvM as new hazard classes;
· · filed 21 May 2021 · source
Mr Eramet wished to highlight the progress made over the last decade in the classification, labelling and packaging of chemicals. We therefore consider that it is too early to propose a revision of the CLP Regulation and we warn against the risk of complicated procedures.
Filed in French · English published by the European Commission
The EU needs a general simplification of its chemicals legislation and a chemicals policy, which is more inclusive for SMEs. The Commission should give high priority to this aspect during the evaluation of the CLP Regulation. In more detail SMEunited suggests: The introduction of a mechanism to remove CLI entries, which have been inactive for a longer period of time (e.g. 3 years).
For some Hazards there is very little nuance between different risks or application. e.g. Risk for eyes is indicated with hand symbol (GHS05), which is confusing for consumers. Furthermore many of the regular household chemicals have labels which are still too complicated and extensive for many consumers and are therefore ignored.
· · filed 12 May 2021 · source
Introduction of new hazard classes: We do not support the unilateral introduction of new hazard classes (PMT, vPvM and ED) by the EU. Such hazard classes should first be negotiated at UN level and included in the GHS in order to ensure global harmonisation. The EU has already been at the forefront of the implementation of the existing GHS.
Filed in German · English published by the European Commission
· · filed 10 May 2021 · source
It looks like your review of CLP legislation is going in the right direction. Our company continually struggles with getting all the CLP information ( in all the language variants) onto a label, where one product is destined for multiple markets. Therefore, additional flexibility with fold out labels is welcome. Additional clarity for "On Line" purchases also seems sensible, due to the rise off On line activity.
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.