NOTIFICATION OF HAZARD MIXTURES: PRODUCT CATEGORIES

With the introduction of Annex VIII of the CLP Regulation an importer and a downstream user of dangerous mixtures classified for health hazards and physical hazards must notify according to the new legal requirements.

The deadlines for notifications according to the new Regulations are to start:

- consumer use: 1 January 2020

- professional use: 1 January 2021

- industrial use: 1 January 2024

There will be a transitional period for all the substances that have been notified and will have to be reassigned according to the new Regulations. It will be necessary to reassess the products starting from 1 January 2025.

To get ahead, you need to categorize your products according to the European product categorization system (EuPCS).

A hazardous product must be assigned a product category that describes its intended main use: EuPCS contains around 250 of these product categories.

To ensure that EuPCS reflects all user needs, it is possible to request changes to the system using the ECHA contact form. Any change should reflect a real need and be supported by the relevant sector.

Before requesting a modification, make sure that your industry or industry association has been consulted.

We strongly recommend that the discussion on the request takes place at the level of trade associations to ensure that the change is based on the support of the whole sector.

All requests must be accompanied by a written justification. We must ensure that we include the support of the sector as guaranteed.

Requests received from ECHA will be processed through the following steps:

• An impact assessment describing the need to modify the EuPCS and the effects on the designated industry and bodies and the poison centers.
• A consultation with the EuPCS expert group, composed of bodies nominated by the Member States, anti-poison centers and industrial associations involved in the development of the categorization system.
• Sharing of the finalized changes with the competent authorities for REACH and CLP (CARACAL) to guarantee the highest level of harmonization. The changes will be implemented as long as no objections are raised.

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