Article 69 of the BPR regulates the classification and the labelling of biocidal products and, in addition to the information specified therein, also requires labelling in accordance with Regulation (EU) No 1272/2008 (CLP).
Since 2015, substances and mixtures are no longer to be classified, labelled and packaged according to the previous substance directive 67/548/EEC and preparation directive 1999/45/EEC. These directives were gradually replaced by Regulation (EU) No 1272/2008 (CLP). Mixtures that were already on the market before 1 June 2015 had a transitional period until 1 June 2017 to be labelled according to the new regulation. Article 46 of the CLP also sets time intervals for checking compliance with the Regulation at 5-year intervals. The first report was issued in 2012, so Member States are obliged to re-examine the correct application of CLP. This second review started in January 2018. The review will not only check the correct labelling but also the full compliance with the information in the Safety Data Sheet (SDS).
It can be expected that compliance with the classification and labelling obligation will be monitored more closely (enforcement). Furthermore, the CLP Regulation prescribes sanctions in case of violations of the labelling obligation. Depending on the type or container size of your product, labelling according to the BPR and CLP can be a major challenge.
We offer to support you in drafting labels and we also check labels of already existing products.
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Please note: CFCS-Consult GmbH does not prepare and check safety data sheets. Please contact a specialized service provider. We recommend this service provider.
Compliance with the REACH ((EU) No. 1907/2006) and CLP ((EU) No. 1272/2008) regulations as well as compliance with the provisions of the CLP ((EU) No. 528/2012) and their implementation is the sole responsibility of the manufacturer. This also applies to the requirements of product safety and the ban on misleading and improper advertising.