The first REACH registration deadline is coming (November 30, 2010), and everyone is working hard to prepare registration dossiers, communicate with SIEFs, and get their documents in on time. But European Chemicals Agency (ECHA) Executive Director Geert Dancet reminded people attending a REACH conference in Helsinki - "Don't Forget the CLP."
CLP is, of course, the new Classification, Labeling and Packaging regulation in Europe. It implements the European version of the Globally Harmonized System of classification and labeling. And the deadline for notification for the CLP is January 3, 2011, just about a month after the first REACH registration deadline.
Companies that are registering in November will most likely be including the CLP notification as part of their registration package. But registrations are due only for those chemicals produced in amounts greater than 1000 tons per year and/or are considered substances of very high concern (SVHCs). Companies who produce or import smaller tonnages won't have to register their chemicals until 2013 or even 2018.
But the CLP notifications are due by January for all chemicals. And while ECHA anticipates anywhere from 25,000 to 75,000 registrations this year, they expect to see about 2 million notifications relating to the CLP. Each one of those CLP notifications requires companies to say whether their chemicals would be classified as dangerous according to dozens of different measures, including physical-chemical properties, whether they are CMRs (carcinogens, mutagens, or reproductive toxins), PBTs (persistent, bioaccumulative and toxic), or toxic to aquatic organisms.
Of the 2 million notifications expected by the beginning of the year, so far ECHA has received only 1,000.
Clearly companies have a lot of work still to do!
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