On February 1, 2018, the 8th amendment to CLP Regulation no. 1272/2008 entered into force.
It sets forth that by the end of the transition period - January 31, 2020 - all safety data sheets and labels must be updated with the new H and P phrases. These are phrases concerning the hazards and precaution from Paragraph 2 of the safety data sheet.
Until the end of January 2020, old H and P phrases may still be used. But be advised, this applies only to the products placed on the EU market before February 1, 2018.
How will you know if the products were placed on the market before this date?
To understand this easily, here are two practical examples.
First of all, if the company received the products to its warehouse before February 1, 2018, this means that the first movement in the EU was done before this date. In this case, Slovenian companies have 2 more years to coordinate the labels.
What is important is the date of the product’s first entry on the EU market (in the entire supply chain).
Another example.
German company A places the product on the market on January 1, 2018 for French company B. Company B sells the product to a Slovenian company on March 1, 2018. In this case, the Slovenian company is not obliged to relabel the product since the product was on the EU market before February 1, 2018.
How does this amendment affect your business?
If you are our VIP client, that is if we provide you ChemiusExpert services, you don’t need to do anything.
We will take care of everything for you by the end of March with no additional costs. Even more, we will take care of the “archives” for the transitional period and provide you with double safety data sheets.
This means that before entering changes to the affected products, we will save your existing safety data sheets. The Chemius application will provide you with the new safety data sheets as well as with the previous one with the text from the old H and P phrases.
If we don’t provide ChemiusExpert services for you and you don’t want to entrust us with this task, then you must make sure to do what is required by the deadline, that is January 31, 2020. This basically means that you will:
- adjust your safety data sheets as appropriate;
- adjust the labels in accordance with the altered safety data sheets as appropriate;
- relabel the products;
- send or enable access to the new safety data sheets for your clients and the people in the entire supply chain.
As previously mentioned, you may still use the old H and P phrases until the end of January 2020 for the products placed on the EU market before February 1, 2018. If you have already printed labels for such products, you can easily use them.
If you believe you need help, you can always contact us.
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