By Ashley Goldie, Sales & Marketing Director, Kallik
There are two things you need to know about CLP – the European Union’s rolling programme to harmonise the way we tell consumers and users about the contents of the products they are about to buy from us:
One, the ticking of the clock to be all set and ready for this should be getting louder and louder in your ears. Basically, you need to be done and dusted with this stuff by the end of May next year – leaving you eight clear months to be ready.
The second thing you need to know about CLP: it’s not just an artwork change.
It is looking to shape up to be a labelling size change, too – perhaps necessitating up to 30% bigger areas to display all the new stuff you need to.
Which, if you haven’t planned for it, could present you with some nasty surprises and last minute issues come May 31st 2015.
We have been working with customers on CLP for some time at Kallik – but the scale of change people are reporting back to us that is required here is genuinely surprising.
In fact, we are so concerned about the scale of the CLP work which organisations in not just the chemicals area, but in many sectors need to do, that we are running a special educational webinar (click here to register: https://www1.gotomeeting.com/register/296033369)about it next week that we’d encourage you to attend.
We know that many people are aware of this key Classification, Labelling and Packaging EU regulation, which is the way Europe is going to get on the same page of the book as the GHS (Globally Harmonised System), the UN’s internationally-agreed standard way of creating a common global way for organisations to communicate on the potential hazards of chemicals. You are probably equally aware of how CLP complements another key EU regulation, REACH – Registration, Evaluation, Authorisation and Restriction of Chemicals.
In the seminar we are sharing some genuinely new information with anyone involved in compliance around packaging and labelling that’s coming back from the front line: it’s a bigger job than we thought.
Every part of your supply chain
Let’s explain why.
There’s a lot of new stuff that’s coming in. Briefly, these are new classification criteria for hazards, new symbols (pictograms) to show what hazards could be and a set of new risk and safety statements.
So in the first category, think toxicity, skin or eye irritation warnings (as well as many more); in the second, you need to be getting your new red diamond border graphic to contain things like the exclamation mark if your product contains a chemical deemed to be capable of causing harm; and in the latter, you need to not just be changing/adapting the risk statements you may already be using, but also feeding in the new approved precautionary statements which you need to be putting on what you offer the trade or the public. (All of these changes need to be applied to products labels, packaging and safety data sheets.)
Now this is where it starts to get more onerous. One, the EU has lowered the barrier for how big the quantity of chemicals needs to be in a product for it to trigger the need for a CLP update. So, first off, check that products you haven’t had to cover under this don’t now fall under the ruling.
Second, while the large companies in the chemical sector are on top of this, we use chemicals in so many parts of the economy now – not just industry but the consumer space, too – so that if you are in personal care, or in DIY/household, or the medical devices space, or in the cosmetics world, there is a high chance that you offer things to the market that are going to be CLP-impacted.
And, even if you are aware of all this and don’t need to start from scratch, we are genuinely being told by first adopters that CLP means not just new symbology, but new and more words and information needing to be displayed.
That potentially means larger labels –that all have to include the right symbols and phrases.
And they all have to be on the shelves or in your supply chain by 1st June next year.
Let’s work through this in good time
You really do need to start looking at this.
And the sooner the better really is going to save you possible time and money hassles as we move into 2015.
Please – take advantage of the webinar (https://www1.gotomeeting.com/register/296033369) next Tuesday September 23, at 2.00-2.30pm BST, and find out what you do or don’t need to do to meet the CLP challenge!