Biocide and Plant Protection Products – don’t get caught out by CLP

Under the new CLP Regulation manufacturers and importers are required to notify the classification and labelling (C&L) of substances to ECHA from 1 December 2010.

Who needs to notify?

The requirement to notify applies to manufacturers and importers for:

1.     Substances (either on their own, in mixtures and those in articles) that are subject to registration under REACH.

2.     Substances not subject to REACH that are classified as hazardous irrespective of tonnage.

3.     Substances classified as hazardous that are present in mixtures, where these are above specified concentration limits (irrespective of tonnage).

Notification to ECHA applies unless the C&L (according to CLP) has already been included in a REACH submission by the time the notification is due.

CLP - biocides and plant protection products

If you are a manufacturer or importer of plant protection or biocidal active substances or products you should ensure that you have met your obligations under CLP.

Although your active substance may be exempt from registration under REACH, it is likely that you will still have the obligation to notify C&L under CLP. 

This is because a notification according to CLP will not have been made, unless you have submitted a REACH dossier (including the classification according to CLP) for other uses that are not exempt from REACH.

What do I need to do?

If you manufacture or import plant protection or biocidal active substances or products you should check your status under CLP.  Where necessary, you should ensure that substances are notified to ECHA within the deadline specified.  For substances on the market on 1 December 2010, the deadline for notification is 3 January 2011.

You should also remember that notification also applies to co-formulants and ensure that these are notified where required and by the specified deadline.

At JSC we are able to advise you on your obligations under CLP and prepare notifications where necessary.  For further information please contact us: Tel:  +44 (0)1423 520245; email enquiries@JSCI.co.uk or visit our website: www.jsci.co.uk