Before I answer the interesting question above, let's quickly repeat - the deadline for updating your safety data sheets in accordance with the Amendment to Regulation (EC) no. 1272/2008 (CLP) for the purposes of its adaptation to technical and scientific progress (18th ATP - Regulation (EU) 2022/692) expires on 1st December, 2023.
The changed classifications included in the 18th ATP must be used from 1st December, 2023 (the entire document can be found at this link). After this date, the new classification is mandatory.
What to do before this date?
Before this date, you can also already apply the new classification and place the product on the market with this new classification. Let me add that from 23rd May, 2022 (20 days after the publication of the 18th ATP) and until 1st December, 2023, both classifications are appropriate - either the old or the new one, in accordance with the 18th ATP.
What about existing stocks of products that are already on the market?
In fact, it is not clearly stated anywhere in the legislation, so it is a "grey" zone. In principle, however, it would be necessary to take into account the new classification, which ultimately means a lot of additional work. This is a very problematic issue because a product shelf-life is often much longer than the time between ATP entering into force and its mandatory deadline for updating.
If you have any additional questions regarding the 18th ATP or any other areas of chemical legislation, feel free to contact me on my email address - tim.bencik@bens-consulting.eu.
Author of the original photo pressfoto portal Freepik
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