Annex VIII: what does it bring to the table?
According to Article 45 of CLP regulation, importers and downstream users who put hazardous mixtures on the market must notify relevant information concerning emergency health response to appointed bodies.
The publication of Regulation 2017/542 takes the place of CLP Annex VIII with the aim of harmonizing this submission process, as well as the data format, for the whole EU.
Last January 10th the European Commission published the Regulation 2020/11, amending Annex VIII to CLP.
Regulation 2020/11: what’s new?
Among the most relevant changes, Regulation 2020/11 foresees:
- The deferral of the first compliance date for mixtures for consumer use from January 1st 2020 to January 1st 2021,
- Some clarification regarding the positioning of the UFI code on the label or on the packaging
- The removal of the GPI “fragrances”
- The possibility to indicate a “contact point” to be used for obtaining further information relevant for emergency health response different from the notifier
- For a Mixture in Mixture (MiM), if neither the full composition nor the UFI are available, it is necessary to notify the composition present in the Safety Data Sheet of the supplier instead of the whole supplier's Safety Data Sheet
- Additional information regarding pH in case of a solid mixture and, if pH is not available, the reason shall be given.
A second update is expected during 2020
The European Commission is also working with solving some of the issues raised by stakeholders and national authorities about the workability of the notification requirements, such as the impact of multiple suppliers of MiMs (Mixtures in Mixtures) with the same technical properties and hazards.
Another update of Annex VIII is expected during 2020, before the first compliance date when importers and downstream users are required to start complying with the new rule.
Trace One is following the development of this situation with maximum attention and we will keep you updated.
To access Reg. (EU) 2017/542 and the text of the delegated act of the amendment, please use the following links: