The 21st ATP to the CLP Regulation brings important changes regarding new and existing harmonized classifications and labeling of chemicals in the EU.
The 21st ATP was accepted to adapt the rules according to the latest scientific findings and international standards and includes the following key points:
1. An additional 28 entries have been assigned a harmonized classification. The existing list of substances with harmonized classifications is available in the CLP Regulation, in Annex VI. You can find a list of additional entries in the 21st ATP.
Example:
- Cinnamaldehyde (with isomers) (CAS: 104-55-2; 14371-10-9) - harmonized classification: H317; c ≥ 0.01%
- Nonylphenol, branched and linear, ethoxylated (CAS: multiple numbers) - harmonized classification: H400 and H410, M-factor 10.
2. The harmonized classification has been updated for 24 entries. These entries are already included in Annex VI, but a re-assessment of their hazards has led to a change in classification.
Example:
- Lead massive: [particle diameter ≥ 1 mm] (CAS: 7439-92-1) - harmonized classification: H360FD, H362, H410 M-factor 10.
- Benzyl alcohol (CAS:100-51-6) - harmonized classification: H302, H317 1.B and H319.
- 1,2-Benzisothiazol-3(2H)-one (CAS: 2634-33-5) - harmonized classification: H302, H315, H317 1.A c ≥ 0.036%, H318, H330, H400, H410.
3. Additions and improvements: In addition to changes and new entries, the 21st ATP also introduces modifications to the criteria that define how hazard types are evaluated.
4. Changes in labeling and packaging: The 21st ATP introduces new requirements for the labeling and packaging of substances and mixtures, impacting how companies must update their chemical documentation.
5. Deadline: 21nd ATP becomes binding on September 1, 2025, which means that companies must adapt their products to the new requirements by that date.
What does this mean for you as manufacturers, distributors, and users of chemicals?
Companies producing, importing, distributing, or using chemicals in the EU must carefully review the changes introduced by the 21st ATP and check if these changes affect their products.
The review involves determining whether any of the entries listed in the 21st ATP are present in the company's product range, either as a substance or as part of a mixture. If necessary, classification and labeling, safety data sheets, labels, technical data sheets, and online store information should be updated accordingly.
In some cases, it might even be necessary to change the product formulation to ensure continued compliance. To ensure compliance by September 1, 2025, this review should be conducted as soon as possible.
We can assist you with this process as well.
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