Dr Colin Hewlett
Chemicals and Transport Limited
Supply – CHIP4 Regulations – Chemical (Information and Packaging for Supply) Regulations 2009
CHIP4 which came into effect on 6 April 2009 consolidated CHIP3 and subsequent amendments; it continues to implement the EU Dangerous Preparations Directive and the Dangerous Substances Directive as an interim measure before REACH and CLP come into full force in 2015. The approved Classification and Labelling Guide (ACLG 6th edition) has been issued as a supporting document to CHIP4 but the Approved Supply List has not been re-issued as its provisions are now included in the EU CLP Regulations. CHIP4 does not specifically regulate Safety Data Sheets since the Safety Data Sheets Directive has now been repealed and its measures incorporated into the REACH Regulations.
The REACH regulations (Registration, Evaluation and Authorisation of Chemicals) which came into law (direct acting EU regulation) in June 2007 have superseded the Safety Data Sheet requirements of CHIP. REACH came fully into effect in June 2008 when the first stage of pre-registration of chemicals began.
o Pre-registration of phase-in substances: 1 June - 1 December 2008
o Potential registrants who for the first time manufacture or import a phase-in substance in a quantity of ≥1 tpy after the pre-registration deadline (later than 1 December 2008) may submit a pre-registration dossier within six months of first manufacturing or importing or using the substance and no later than 12 months before the relevant registration deadline
o Registration of substances that have been pre-registered, all substances supplied at ≥1000 tpy; ≥100 tpy R50/53 substances and ≥1tpy class 1 and 2 CMRs before 1st December 2010
o Information on classification and labelling of all substances subject to registration or classified as hazardous submitted to ECHA for inclusion on inventory: 1st December 2010
o Registration of substances that have been pre-registered, tonnage 100-1000 tpy before 1 June 2013
o Registration of substances that have been pre-registered, tonnage 1-100 tpy before 1 June 2018
o Substances which have not previously been placed on the EU market (non-phase-in substances) and phase-in substances which have not been pre-registered must be registered before manufacture or import.
By means of the CLP (Classification Packaging and Labelling) Regulations implements GHS (global harmonisation system of classification & labelling)
The CLP regulations (EC) No 1272/2008 on the Classification, Labelling and Packaging of chemical substances and mixtures, which implements the UN Globally Harmonised System (GHS) at EU level, entered into force on 20 January 2009. The deadlines for implementing the new system are 1 December 2010 for substances (coinciding with the first registration deadline for phase-in substances), and 1 June 2015 for mixtures.
The CLP Regulation will gradually replace the current rules of Directives 67/548/EEC for dangerous substances (DSD) and 1999/45/EC for preparations (DPD) as implemented by the CHIP regulations in the UK (CHIP4) during a transition period ending on 1 June 2015, when both Directives will be definitively repealed.
The transfer of Annex I entries to Annex VI did not include the 30th and 31st amendments to technical progress (ATP) of the DSD, which were adopted before the entry into force of the CLP Regulation but this has now been accommodated with the publication in August 2009 of the first ATP to the CLP Regulation (EC) 790/2009 (enforceable from 1st December 2010).
CLP deleted Title XI of REACH on the “classification and labelling inventory” and transferred an amended version of these provisions under Chapter 2 of Title V of the CLP Regulation itself. The obligation to notify the new CLP classification and labelling of substances by 1 December 2010 also applies to all substances placed on the EU market that are classified as “dangerous” (“hazardous” under the CLP), not only those that require registration by that date. This applies to all manufacturers and importers of dangerous substances including those present as components in mixtures whatever the volume so a substance can be subject to notification for the C&L Inventory even if exempted from registration under REACH.
The Globally Harmonised System of Classification and Labelling of Chemicals (GHS) aims to provide a framework to bring together the various national and regional hazard communication systems which control the supply of hazardous chemicals in much the same way that the ‘Orange Book’ offers a global framework for the transport of dangerous goods. The purpose of GHS is to provide a single globally harmonized system to address classification of chemicals, labels, and safety data sheets.The first edition of GHS was published in July 2003 as the ‘Purple Book’ and revisions published bi-annually.
Last updated: July 2013