CLP Update: Europe – The 21st ATP -what you need to know to comply
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SDS
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CLP
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Regulatory
Posted By:
Ilaria Finazzi
There’s much to follow with the recent changes to the European ATP (Adaptation to Technical Progress) of CLP (Classification, Labelling and Packaging) of hazardous substances. Released in January, it includes updates to harmonized classification and labeling of certain substances, according to the relevant opinions adopted by the RAC (Risk Assessment Committee of the European Chemicals Agency).
Managing these updates manually is cumbersome, and any safety professionals still doing so are likely looking to upgrade their regulatory systems and workflows to respond. To keep up, they are obtaining digital manage EU regulatory changes and using these tools to streamline workflows, as well. Over 600 companies already use Trace One SDS worldwide—and they do it in 47 languages and counting.
What’s at stake? Keeping current products on the market and being able to launch new ones with regulatory issues taken care of in advance. Fortunately, you can safeguard their reputation, ability to launch and quickly respond to regulations within Trace One SDS. You can integrate with existing ERPs and other systems to make sure there’s one version of the “regulatory truth,” companywide.
For example, some chemical companies that have invested in forward-looking digital product lifecycle management (PLM) tools are already voluntarily complying with the specific regulations in the 21st ATP updates to Annex VI. There are 24 changes to existing entries and 28 new harmonized substances included within that update.
One example of many
Methyl acrylate, CAS 96-33-3 is used in acrylic fibers, fiber processing agents, molding resins, adhesives, paints, coatings, and emulsions. It carries a variety of hazard classifications, however, the recent changes in the 21st ATP are related to the Acute Toxicity hazard and Acute Toxicity Estimates. After the deadline, products must be classified and labelled according to the ATP21 changes. If manufacturers plan these changes well in advance of the 1 September 2025 deadline, they can ensure their customers won’t experience delays.
Trace One SDS software allows you to run a query and get a report of which products in your portfolio contain a substance that has been updated by the regulation. Then, by updating your labelling and safety data sheet (SDS) workflow, you can mitigate risks of not meeting compliance on time. If these products include a UFI/PCN notification requirement, these can also be updated within Trace One SDS. You can even run batch operations for these after working hours.
Other chemicals in the 21st ATP include:
- Sodium chlorate (EC number: 231-887-4, CAS number: 7775-09-9)
- Lead powder (particle diameter < 1mm) (EC number: 231-100-4, CAS number: 7439-92-1)
- Lead massive (particle diameter >= 1mm) (EC number: 231-100-4, CAS number: 7439-92-1)
- Benzyl alcohol (EC number: 202-859-9, CAS number: 100-51-6)
Certain nonylphenol ethoxylated isomers also are among the newly added entries.
Of course, your activities to manage these changes will vary according to the systems and processes you already use. But here are three ways Trace One SDS companies manage them:
3 Steps to Compliance
- Identify Affected Products: Use Trace One SDS to query for methyl acrylate and other affected ingredients.
- Identify Alternatives (Optional): Search Trace One Devex PLM for substitutes. This step is often unnecessary in the chemical industry due to formulation restrictions and the unique chemical properties each manufacturer needs within their formulations.
- Create Labelling and SDS Process: Use Trace One SDS to gain cross-functional approvals, and generate forms and workflows for labels, SDS, and any UFI/PCN notifications needed.
Trace One SDS libraries are updated regularly with new regulations and deadlines. And yes, most people responsible for regulatory compliance receive notifications and emails about these from a number of sources. With Trace One SDS, you can search within your products to see which contain chemicals impacted by new regulations and be prepared well in advance for changes—far in advance of the 22nd ATP, whenever it’s released.
To find out how much money and time you can save with Trace One SDS, answer this six question quiz: Take the quiz.