Important information regarding new CLP regulation

Published December 19th, 2012

Board of Nordic ecolabelling approved at its meeting 14 December 2012 an amendment to the techno-chemical criteria regarding environmentally hazardous substances.

New requirements of labeling and packaging of hazardous substances ( CLP regulation) came in force December 1st 2012. From now on companies must re-label and re-package in accordance with the CLP Regulation all substances that are currently labeled and packaged according to the Dangerous Substances Directive (DSD, directive 67/548/EEC). In practice, this means that the old risk and safety phrases (R- and S- sentences) will be replaced by hazard and precautionary statements (H- and P- sentences).

At the same time the requirements of environmental hazard classification criteria will change. In the CLP classification system, the long-term aquatic hazard classification categories (H410, H411, H412) can be based on chronic toxicity of substance. Therefore substance may be classified as long-term hazardous to the aquatic environment, even though the substance is readily biodegradable (if there is data for chronic toxicity). This may have some impact on the substances, which are not previously classified as hazardous to the environment, but for which there is data of chronic toxicity. Especially this will affect surfactants, which often have low toxicity values but are readily biodegradable. In consequence different suppliers may classify surfactant differently depending on available data.

Nordic ecolabelling has had dialogue with some raw material suppliers about the consequences of the change. We have also gone thoroughly through the requirements of different techno-chemical criteria and examined a large number of product recipes to evaluate the consequences of CLP to ecolabelled products. Based on this we have changed our techno-chemical criteria. We have excluded surfactants that are classified H411 and/or H412 from the requirement about environmentally hazardous substances in certain criteria, provided the surfactants are readily and anaerobic biodegradable.

This is on condition that the end product is not classified as dangerous for the environment / hazardous to the aquatic environment. If the product is classified as hazardous to the aquatic environment, modifications in recipe are needed in order to maintain the license. Nordic ecolabelling encourage license holders to contact national organizations in good time, if product is classified as hazardous to the aquatic environment. A transition period of six months may then be granted.

New modified versions of the criteria will be published soon. The changes are listed briefly below.

Surfactants classified as H412 exempted

• 006 Laundry detergents and stain removers ver. 6 (valid until 31.3.2013)
• 006 Laundry detergents and stain removers ver. 7 (valid until 31.12.2015)
• 013 Car and boat care products ver. 4 (valid until 30.6.2013)
• 017 Dishwasher detergents ver. 5 (valid until 30.6.2014)
• 026 Cleaning products ver. 4 (valid until 30.6.2014)
• 051 Floor care products ver. 3 (valid until 31.10.2013)
• 051 Floor care products ver. 4 (valid until 31.12.2015)
• 065 Industrial cleaning and degreasing agents ver. 2 (valid until 30.6.2014)
• 070 Cleaning agents for use in the food industry ver. 1 (valid until 30.6.2014)
• 080 Dishwasher detergents for professional use ver. 2 (valid until 30.6.2014)
• 093 Laundry detergents for professional use ver. 2 (valid until 31.12.2014)

Surfactants classified as H411 exempted

• 025 Hand Dishwasher Detergents ver. 4 (valid until 31.3.2013)

Surfactants classified as H411 and H412 exempted

• 013 Car and boat care products ver. 5 (valid until 31.3.2015)
• 025 Hand Dishwasher Detergents ver. 5 (valid until 31.3.2016)
• 090 Cosmetic products ver. 2 (valid until 31.12.2014)