The aim of the CLP Regulation is to inform stakeholders in the supply chain and the general public about the potential hazards of substances and mixtures. The German Chemical Industry Association (VCI) supports the current revision of the CLP Regulation in principle, but at the same time expresses clear concerns regarding the adaptation of labels, the classification of substances with more than one component and the increased use of substance groupings.
"Particularly against the backdrop of the current tense economic situation, such measures will only create additional burdens for companies. It is important that practical assistance and guidelines are made available to companies quickly so that implementation runs as smoothly as possible," says Ulrike Zimmer, Head of Technology and Environment at the German Chemical Industry Association (VCI).
VCI advocates quality over quantity
The redesign of labels due to new formatting requirements represents a considerable financial burden for the industry without any recognizable added value for end consumers or professional users. Furthermore, in future, substances are to be assessed more on the basis of their individual components and less on the basis of the substance as a whole. As a result, many currently safe substances will have to be re-evaluated internally and could be subject to further restrictions and bans in the future. The VCI is also critical of the increased use of substance groupings in which different substances with structural similarities are evaluated together. This could result in relevant information on individual substances being lost. Quality should continue to take precedence over quantity in hazard assessment.
The VCI takes a positive view of the introduction of digital labels, which should make it easier for end users to access relevant information in future. Equating folded labels with traditional labels is also a benefit for the industry in terms of multilingualism. The VCI is also in favor of chemicals being able to be dispensed in so-called refill stations without disposable packaging in the future.
Background to the CLP discussion
At the end of 2022, the EU Commission presented proposals to amend the CLP Regulation (Regulation on Classification, Labeling and Packaging of Substances and Mixtures). The CLP revision is a component of the EU Commission's "Chemicals Strategy for Sustainability" published in 2020. With numerous measures to protect health and the environment, it is part of the European "Green Deal" and will have far-reaching consequences for the industry.
The VCI and its trade associations represent the interests of around 1,900 companies from the chemical-pharmaceutical industry and chemical-related industries vis-à-vis politicians, authorities, other sectors of the economy, science and the media. In 2022, the member companies of the VCI had a turnover of around 260 billion euros and employed almost 550,000 people.
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