If you’re involved in scientific research and development, you may believe the substances and mixtures you use are exempt from CLP (Regulation (EC) No 1272/2008) obligations.
While that’s true in specific cases, the situation becomes more complex when these substances or mixtures leave your hands. Let's dive into this subject and see what are the myths and what you're obliged to do.
Now, under CLP, substances and mixtures used solely in scientific experimentation, analysis, or research are exempt—provided they are not placed on the market and are used under controlled conditions in line with EU workplace and environmental legislation. However, as soon as you supply or physically make these substances or mixtures available to another legal entity, such as sending samples from one university to another research institute or importing them, this is considered "placing on the market" (CLP Article 2(18)).
This shift changes everything. Now, the supplier or importer must classify the substances or mixtures based on available information, label and package them per CLP requirements, and, if hazardous, notify the Classification & Labelling (C&L) Inventory.
Ignoring these obligations can lead to compliance violations, legal consequences, and potential harm. Don’t let assumptions jeopardize your work. Take a moment to review your processes. If you’re sending or receiving samples, ask yourself: Are you meeting the requirements of CLP?
Your work matters—don’t let regulatory gaps undermine your efforts. Get in touch at luka.rifelj@bens-consulting.eu if you need help with chemical regulations.
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