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European CLP regulation amended again: apply to you?

On Feb. 18, 2020, the European Union published the new Delegated Regulation EU 2020/217. This Regulation aims to amend and correct the existing CLP Regulation EC 1272/2008 on the classification, labeling and packaging of chemical substances and mixtures. We have provided insight into these changes for you.

New EUH sentences for mixtures containing titanium dioxide (titanium dioxide)

The main change in the CLP Regulation relates to the addition of two additional labeling elements (EUH phrases):

  • EUH211 - "Caution! Hazardous inhalable droplets may be formed when atomized. Do not inhale spray mist."
  • EUH212 - "Caution! Hazardous inhalable dust particles may be formed during use. Do not inhale dust."

These phrases must be used on packaging by Oct. 1, 2021, in the following situations:

  • EUH211 applies to liquid mixtures containing 1% or more titanium dioxide particles with an aerodynamic diameter of 10 μm or less.
  • EUH212 applies to solid mixtures containing 1% or more titanium dioxide.

The official translations of the two new EUH phrases are also attached in the regulation.

Titanium dioxide in products

Titanium dioxide has several functions and thus is used for a variety of applications. Because of its bright white color, it is often used as a dye in inks, paints and correction fluids. Because titanium dioxide also absorbs and reflects ultraviolet radiation, the substance is also often used in sprays for treating (outdoor) textiles. If you sell such products on the European market, it is therefore important to assess whether you need to revise your packaging.

Other changes

In addition to the two newly added EUH phrases for mixtures containing titanium dioxide, Regulation EU 2020/217 includes the following changes:

  • Two substances (with catalog numbers 604-083-00-X and 611-159-00-6) are removed from the table of substances with harmonized classification in Annex VI of the CLP Regulation;
  • Twelve entries in the table of substances with harmonized classification in Annex VI are revised;
  • 17 new substances are added to the table of substances with harmonized classification;
  • The classification of pitch and coal tar (high temperature) with CAS number 65996-93-2 is clarified in Annex VI.

All amendments will take effect Oct. 1, 2021, with the exception of those related to pitch and coal tar (CAS number 65996-93-2). These amendments have already been in effect since December 2019.

What do the changes mean for you?

The changes in the CLP Regulation may affect the hazard classification of your mixture(s). If you sell mixtures containing titanium dioxide on the European market, you may need to use the new EUH phrase(s) on your packaging.

In addition, using the harmonized classification of substances (if available) is a legal requirement. If you use substances in your mixtures for which a harmonized classification has been added to the CLP Regulation, this may affect the hazard classification of your mixture(s). Your product may be classified differently than before and you may need to adjust your packaging accordingly.

If your mixture contains substances for which there is a change in the CLP Regulation, it is important to update the SDS as well. Use the information in Section 2 of your SDS to re-evaluate and possibly change your packaging.

Need help?

Do you need help assessing your mixture(s) according to the latest changes in the CLP Regulation? Or are you looking for a party who can prepare a new safety data sheet for your mixture? We can offer you support and would be happy to meet with you!

Please feel free to contact us at +31 (0)30 - 65 66 010 or info@precongroup.com

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