GHS - CLP

= Globally Harmonized Systems of Classification, Labelling and Packaging

FEICA position on the Proposal for a Regulation of the European Parliament and of the Council on classification, labelling and packaging of substances and mixtures, and amending Directive 67/548/EEC and Regulation (EC) No 1907/2006

FEICA the European Adhesive & Sealant Manufacturing Association is a multinational association representing the European Adhesive and Sealant Industry. With the support of 15 national associations and several direct and affiliated members, FEICA coordinates, represents and advocates the common interests of our industry throughout Europe. In this regard FEICA aims at establishing a constructive dialogue with legislators in order to act as a reliable partner to resolve issues affecting the European Adhesive and Sealant Industry.

FEICA welcomes the Commission proposal and hopes that it will lead to an approximation of global classification and labelling rules. There are, however, some points of concern for FEICA in the existing proposal.  These concerns have largely been addressed in comments on the proposal submitted separately by the European Chemical Industry Council (CEFIC), Downstream Users Chemicals Co-Ordination Group (DUCC), British Adhesives and Sealants Association (BASA) and Verband der Chemischen Industrie (VCI). FEICA supports the comments submitted by these organisations, with the exception of the following specific points:

• FEICA strongly agrees with the comments made by DUCC regarding the practical application of bridging principles for the classification of mixtures. Article 9 of the proposed Regulation specifies that the classification methods described in parts 3 and 4 of Annex I may only be used if there is no test data on the mixture and there is insufficient information to permit the application of bridging principles. This would present significant difficulties for SMEs that do not have the necessary resource and expertise to apply bridging principles and who currently rely on the use of electronic systems for the classification of their products. Article 9 should be revised to give use of the classification methods described in parts 3 and 4 of Annex I equal precedence with the application of bridging principles.
  
• FEICA believes that the comments made by VCI regarding Article 26(1) and concerns over intellectual property if this Article is not extended to include use of generic names in safety data sheets fail to take account of provisions already included in Annex II to Regulation (EC) No 1907/2006 (REACH). Section 3.6 and the footnote to Section 3.3 of Annex II to REACH already provide for the use of generic names in safety data sheets to protect confidential information, so there is no need to extend the application of these provisions in the proposed Regulation. Article 56 of the proposed Regulation should include provisions for amendment of Annex II of REACH to ensure that references to Directives 67/548/EEC and 1999/45/EC are replaced with references to the new Regulation at the appropriate times. These provisions are not currently included and must be added.

FEICA also has some concerns regarding the labelling requirements for small packages set down in the proposed Regulation. These are addressed in a separate FEICA position statement on the specific topic of small packages.

The CLP Regulation was published in the Official Journal (OJ L 353) on 31 December 2008 (click here, 1355 pages).

FEICA flyer explaining the basic changes in the Classification and Labelling
(, 4 pages).

February 14^th 2008