Irantzu Garmendia is an extremely well prepared technician of REACH Ederto. Probably one of the best experts in REACH and CLP of the Basque Country.
She sends me a comment about de 1st adaptation of GHS in European legislation, published on 5th of September in the Official Journal.
She is as grave as well knower of the regulation and she doesn't make any joke about the fact that a regulation needs an adaptation to technical progress one and a half year prior its coming into force…. I’m sure a record has been beaten in this affair!.
Our followers know that this blog uses to publish the entries about REACH an CLP (Chemicals Labelling and Packaging) in English…. hoping that anyone, In Brussels or Helsinki, surfing the net, meet us and receive a distant echo about what the small and medium size chemical companies think about this matter…..
The inclusion of a substance in the Annex I of the Directive 67/548/CEE supposes the legal obligation of using this classification and labelling in all commercialization of the product. The ATP (Adaptation to technical and scientific progress) amends the Annex I of the Directive 67/548/CEE by means of the introduction of new and upgraded harmonized classifications.
The August 21st of 2008 is published on the Official Journal of the European Union the Directive 2008/58/CE, which adapts to the technical progress for the thirtieth time the Directive 67/548/CEE and fixes its transposition to the Member States legislation by June 1 2009.
The 31st of December of 2008, the publication on the OJ of the EU of the Regulation 1272/2008 or better known as CLP, introduces in Europe the new regulation for harmonized classification and labelling (in accordance with the GHS recommendations of the UN) that supposes the future amendment and repeal of the Directive 67/548/CEE of substances (December 01 2010) and of the Directive 1999/45/CE of prepared (December 01 2015). The 30ª ATP is not included in Annex VI of this Regulation that replaces to the Annex I of the Directive 67/548/CE. Things begin to complicate.
Surprisingly January 16th of 2009 is published on the OJ of the EU the Directive 2009/2/CE, 31st ATP of the Directive 67/548/CEE, that imposes the same implementation terms that for the 30th ATP, the 1st of June of 2009. These harmonized classifications neither have been incorporated to the Annex VI of the CLP.
Keeping in mind that the Annex I of the Directive 67/548/CEE is deleted by the article 55.11. of the CLP, and that the classifications of the Directives 2008/58/CE and 2009/2/CE are not included in part 3 of the Annex VI of this Regulation, many were the doubts that the industry thought about like what relevance they have the classifications of the Directives?, Which classification should be implemented? And which are the deadlines for these implementations?
The Commission has worked very hard to give answers to all these questions and, one year an a half before even completely entering into force, the CLP, has already its 1st ATP in order to transfer to the Annex VI the harmonized classifications contained in the Directives 2008/58/EC and 2009/2/EC. This ATP is a regulation and therefore of direct execution in the whole UE.
The publication of the Regulation 790/2009 was made the 5th of September, while some of us were still landing from a well deserved vacation time. The Regulation contains 5 annexes, with the lists of entries to be replaced, inserted and deleted from table 3.1. with the list of harmonised classification and labelling of hazardous substances in accordance with the Regulation 1272/2008 and from table 3.2. with the list of harmonised classification and labelling of hazardous substances from Annex I to Directive 67/548/EEC.
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