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Some important notes on Annex VI of the EU CLP Regulation

Posted Date:2024/1/10

Annex VI of the CLP regulations contains a uniform classification and labeling of approximately 7,000 hazardous substances. It is mandatory for suppliers of the corresponding substances or mixtures to apply uniform classification and labelling in order to prepare their GHS labels and safety data sheets. In this article, we will explain the factors to consider when using the uniform classification, focusing on the notes in Annex VI to the CLP regulations.

Using a unified classification will greatly simplify your SDS and label preparation. But sometimes can not blindly refer to the classification in his table, need to pay attention to a few points:

1. For certain hazard classes, including acute toxicity and STOT repeated exposure, the classification in the Annex shall be regarded as the minimum classification.

2, if the manufacturer or importer has more stringent data or other information than the minimum classification. A more stringent classification must then be adopted.

3. For some items (indicated by the reference tag), physical hazards are not included in the uniform classification due to insufficient data. In such cases, the correct classification of physical hazards should be confirmed by testing.

4. Note specific concentration limits and M-factors.

5. Please read the notes to each Annex VI entry (i.e. A, B, H, L, U), which contain the conditions for applying the uniform classification.

Explanation:

1, when some substances in the annex classified as: "acute toxicity - oral, class 4", then the lowest classification of the substance is the above classification, and then according to the measured data will only increase its toxicity classification, will not reduce.

2. Ibid

3, for example, some substances, the list may be flammable solids, but the actual product may be modified, may change its material structure, then the classification needs to be confirmed by actual measurement.

4, some substances in the European Union will have a specific concentration limit, in the United Nations GHS generally less than 0.1% of the substance will not be classified, but in the European Union is not necessarily, some substances have its specific concentration limit. The M-factor is also a factor to be considered in classification.

5, some substances due to its particularity, in the formation of substances may carry some impurities. Then the classification will have several cases, can not be generalized. For example: the NOTE "NOTE L" in petroleum - if it can be shown that the substance contains less than 3% of DMSO extract (according to IP 346' unused lubricating base oil and determination of polycyclic aromatic hydrocarbons in petroleum distillates without asphaltenes-DSO extract), it does not need to be classified as a carcinogen.