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EU CLP Regulation

Less than one year before the 21st ATP becomes mandatory, the European Commission has published the 22nd ATP.

The regulation will enter into force on the 20th of October 2024 and will be mandatory from the 1st of May 2026.

It introduces:

• 27 new entries with harmonized classification,
• 16 modifications to the classifications of existing entries,
• and the removal of 7 entries.

I quickly checked how many products in the portfolios of our customers are affected and found about 7,500 hits—slightly less than 10% of all products. That’s significant, especially since some common chemicals, such as formaldehyde, formic acid, n-hexane, and hexyl salicylate, are affected by this ATP.

It is also worth noting that the classification of silver is now harmonized in three ways based on particle size. The Commission opted for a less strict classification for reproductive toxicity (Category 2, H361f), despite proposals calling for the stricter H360 classification.

Here is a brief overview of the changes covering some of the most commonly occurring substances:

New entries

Substance name Identifiers New classification Remark
hexyl salicylate CAS: 6259-76-3
EC: 228-408-6
H361d, H317 May become forbidden in cosmetics due to H361d
2,4-dimethylcyclohex-3-ene-1-carbaldehyde CAS: 68039-49-6
EC: 268-264-1
H317 Very common in fragrances, but H317 already used in practice
Silver (massive, powder, nano) CAS: 7440-22-4
EC: 231-131-3
H361f, H373 (nervous system), H400, H410 (except massive) M-factor 10 for powder (1000 for nano)
copper [specific surface area > 0,67 mm2/mg] CAS: 7440-50-8
EC: 231-159-6
H400, H410 M-factor (acute) = 10

 

Updates of existing entries

Substance name Identifiers New classification Remark
n-hexane CAS: 121-43-7
EC: 203-777-6
H225, H361f, H304, H336, H372 (nervous system), H315, H411 Occurs in over 2000 products in Chemius
formaldehyde … % CAS: 50-00-0
EC: 200-001-8
H350, H341, H330, H302, H314, H317 H317 is now category 1A
formic acid … % CAS: 64-18-6
EC: 200-579-1
H226, H290, H331, H302, H314, H318 Check the official text for SCL
glyphosate (ISO) CAS: 1071-83-6
EC: 213-997-4
H318, H411 Classification remained the same

Note: Specific concentration limits (SCL) are ommited for clarity

Since the 21st ATP is not yet mandatory, I also invite you to read this post to ensure your chemical documentation is already updated for the upcoming changes. If maintaining an up-to-date database of safety data sheets, labels, and other chemical reports is challenging, please feel free to contact us via email or phone—our help is closer than you think.

Disclaimer:
Information on this blog is prepared with utmost care, but it is not about (chemical) consulting, and the provider does not assume any responsibility or liability for the correctness, accuracy and up-to-dateness of published content. If you need advice for a specific case, you can write to us at bojan.dimic@bens-consulting.eu
SDS | October 1, 2024

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