WTO Circulates Proposed Changes to EU CLP Regulation

The European Union (EU) has informed the World Trade Organization (WTO) that it intends to revise Regulation (EC) 1272/2008 on Classification, Labeling and Packaging of Substances and Mixtures (CLP Regulation).

Among the proposed changes:

  • 39 entries added to Table 3 in Part 3 of Annex VI to the CLP Regulation ‘List of Harmonized Classification and Labeling of Hazardous Substances’ (Table 3). This includes bisphenol S (BPS) as a reprotoxic 1b substance
  • 17 entries in ‘Table 3’ replaced – including new classification and labeling information for bisphenol A (BPA)
  • One entry deleted from ‘Table 3’ – 1,5-naphthylene diisocyanate

BPS is an analogue of BPA and has increasingly been used as an alternative in a variety of applications – e.g., in curtains, flooring, furniture, leather, paper, cardboard and toys.

The WTO circulated this information on August 2, 2021. According to the notification, this draft regulation is proposed to be adopted in Q4 of 2021, with entry into force twenty days after it is published in the Official Journal of the EU (OJEU). It will then become effective 18 months later (possibly mid-2023).

Stakeholders should be aware they can begin conforming to the new requirements once it has entered into force.

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