Retail and Wholesale on hazard classification, labelling and packaging of chemicals (CLP)

Key messages

• Introducing new hazard classes should always be science based.
• Main responsibilities need to remain on manufacturers who have a more complete level of information and are best placed compared to retailers and wholesalers.
• The introduction of digital labels is timely and in line with modern technology and communication channels. However, pivotal information should remain on-pack.
• We support the Commission amendment that Member States may appoint the European Chemical Agency, as a body responsible for receiving the relevant information
• Manufacturers respectively importers should be responsible for ensuring that the substances and mixtures they place on the market are compliant and properly labelled.
• Format of labels - our sector believes it is beneficial to add more information on the digital label and less information on the physical label.
• ATP deadlines be at placing on the market stage so as to allow retailers to use up all stocks.

General remarks

The CLP Regulation is a core piece of Union Chemicals legislation and includes how to communicate identified hazards to consumers and workers, thereby directly affecting retailers and wholesalers who act as distributors and/or as importers of mixtures and products o consumers and professional users, or producers/importers of own-brand products. We advocate for the revision to be workable for all actors in the chain and for the European Commission to consider the latest science and technology advances and market trends, to ensure a level playing field in the internal market and avoid fragmentation of the internal market.

We support the main aims of the CLP Regulation as to ensure both a well-functioning single market for chemicals and a high level of protection of human health and the environment. We fully acknowledge that, if chemical-based hazard exists, it must be communicated in an unambiguous way through pictograms and a consistent approach to the EU hazard-communication system on chemicals.

Simplified rules should be preferred, as to improve communication and strengthen consumers’ understanding of the hazards. This means easy-to-implement rules, further exploration of digital possibilities, and simplification for very small quantities of mixtures. Simplified rules also have a positive cost-benefit ratio for companies. We, therefore, continue to support a proportionate approach to support economic growth and global competition.