UN GHS and EU CLP
The Classification, Labelling and Packaging of Substances and Mixtures (CLP) Regulation (EC) No 1272/2008 is the Regulation which aligns previous European legislation on classification, labelling and packaging of chemicals to the UN Globally Harmonised System of Classification and Labelling of Chemicals (UN GHS). Its main objectives are to facilitate international trade in chemicals, and to maintain the existing level of protection of human health and the environment.
A specific hazard category is dedicated to flammable aerosols under Chapter 2.3 of the UN GHS and under Annex I, Chapter 2.3 of the EU CLP.
Holding a Non-Governmental Organisation status at the UN Sub-Committee of Experts on the Globally Harmonized System of Classification and Labelling of Chemicals (UN SCE-GHS), FEA, together with the Health & Safety Executive (UK), submitted several documents during the biennium 2009/2010 in order to define new global provisions for the labelling of both flammable and non-flammable aerosols.
An agreement on aerosol labelling was reached within the UN SCE-GHS in December 2010 and FEA now favours an official publication into both ADD and CLP Regulations with the purpose of obtaining a full alignment, otherwise it would not be manageable for the aerosol industry and would confuse consumers.
As a result, all European aerosol products will be required to be re-labelled. Modifying the packaging layout of more than 5 billion units takes time. For this practical reason, aerosol manufacturers need a legal clarification of labelling requirements prior to the deadlines confirmed in the CLP Regulation.