Document oeq71a0VOL9NQnRG3BoxgVJOr

8 POINT ACTION PLAN FOR AN EFFECTIVERef. ArReesf(.2A02re2s)(721062426)78048- 61272/160-/20072/122/2022 REVISION OF THE EU CLASSIFICATION, LABELLING AND PACKAGING REGULATION Together with REACH, the EU Classification, Labelling and Packaging Regulation (CLP) is a cornerstone of the EU chemical legislation. Revising CLP means changing the foundation of one of the most comprehensive chemical legislation in the world. This 8-point Action Plan outlines how this can be done in a targeted way so that it effectively tackles the areas where improvement is needed in line with the objectives set in the Chemical Strategy for Sustainability. ACTION 1: ASSESS THE IMPACT OF CLP CHANGES ON OTHER MANUFACTURING SECTORS ? WHY? Adding new hazard classes to CLP will not only affect the chemical industry, it will also have a "ripple effect" on many downstream sectors using chemicals due to automatic links between CLP and sector-specific product legislation (e.g. biocides, pesticides, detergents, cosmetics, toys, medical devices, amongst others). In fact, as many as 12,000 substances might be affected by proposed changes to CLP and GRA (generic approach to risk management). As a result, many products that consumers and professionals rely on may no longer be available on the market. P RESULT: Careful analysis will help identify whether strategic and essential value chains may be negatively impacted by the CLP reform. ACTION 2: AGREE CHANGES TO CLP AT THE GLOBAL LEVEL FIRST ? WHY? EU's CLP is based on the United Nation Globally Harmonised System of Classification and Labelling of Chemicals (UN GHS), which is a key building block for ensuring safety of chemicals all over the world. Making unilateral changes that deviate from the global standard may disrupt global value chains and undermines trust in the well-functioning global system. While it is possible for the EU to propose an update to UN GHS after updating CLP, there is no guarantee that it would be accepted by all parties, meaning that EU CLP may need to be updated several times to realign with the international standard. Adding new hazard classes to CLP now does not add any value from the public health and environment perspective either: EU REACH already regulates all substances that would be covered by adding new hazard classes under CLP. P RESULT: Chemical safety information remains harmonised at the global level with no deviating regional standards. Multiple updates of EU CLP to realign with UN rules are avoided. ACTION 3: ENSURE CRITERIA FOR ENDOCRINE DISRUPTING SUBSTANCES REFLECT THE WORLD HEALTH ORGANISATION'S (WHO) DEFINITION ? WHY? The WHO definition of endocrine disruptors represents the global science-based foundation to identify substances with endocrine disrupting properties. It is also already used in the EU legislation governing the use of plant protection products and biocides. So it is important to keep this definition as a basis for future policy for both category 1 and category 2 sub-divisions. P RESULT: Updated CLP Regulation is built upon evidence- based criteria consistent with the rest of the EU legislation. ACTION 4: ALLOW THE USE OF ADDITIONAL DATA TO CLASSIFY SUBSTANCES AS "MOBILE" UNDER CLP ? WHY? One of the potential changes to CLP is to identify and label substances with Mobile (M) or Very Mobile (vM) properties. However, the technical and policy discussions over the past years have confirmed the absence of a reliable and robust methodology that would make it possible to decide whether a substance can qualify as Mobile or Very Mobile. For this reason, we need to use additional data and "weight of evidence" approach. P RESULT: Evidence-based approach is used to inform decisions concerning this "difficult-to-identify" hazard class. ACTION 5: BETTER PROMOTE THE USE OF DIGITAL SAFETY LABELS ? WHY? CLP revision is an opportunity to modernise the labelling of packaging. In addition to keeping essential safety information on the physical labels, making more use of digitalised labels would make it possible to provide additional information about hazards, safety, and product composition in many various languages online. P RESULT: Digital formats will make labels more consumer- friendly by giving consumers an opportunity to receive even more information about the safe use and in many more languages than one physical label Less crowded labels make safety information easier to read and to understand by users. ACTION 6: ENSURE SUFFICIENT TRANSITION PERIODS TO IMPLEMENT CHANGES ? WHY? The introduction of new hazard classes will require reclassification and new labelling of all substances. Once substances are reclassified and relabelled, mixtures of substances will have to be reclassified and relabelled in turn. Formulators of mixtures first need all new classification information on substances before they can update safety information for mixtures. Therefore, two distinct and successive transitional periods for substances and mixtures are needed: at least two years for substances and three years for mixtures. P RESULT: All manufacturers have sufficient time to implement changes. ACTION 7: ENSURE ONLINE MARKETPLACES COMPLY WITH CLP AND ENFORCE COMPLIANCE FOR ONLINE OPERATORS ? WHY? Online marketplaces are not defined as "economic operators" nor "importers". As a result, EU Member State authorities cannot enforce EU chemicals safety laws for goods sold online, especially if online marketplaces are registered outside of the EU. P RESULT: Making online platforms responsible for the goods they sell will enhance consumer safety. ACTION 8: ENSURE THE EUROPEAN CHEMICALS AGENCY HAS SUFFICIENT RESOURCES AND EXPERTISE TO IMPLEMENT CHANGES ? WHY? Adding new hazard classes to CLP will require the European Chemicals Agency (ECHA) and Member States to significantly increase their resources to handle the workload and process new requirements. ECHA's Committee for Risk Assessment (RAC) will also need to develop new areas of expertise to provide advice on new hazard classes. P RESULT: ECHA has the manpower and expertise to deliver on policy goals and implementation.