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CLP / Poison Center Notification

About CLP: structured, up to date information provided on ECHA webpage free of charge here.  ECHA Legal Notice

ALSTER Consulting provides various services on CLP, such as:

  • General compliance advice
  • Determine the C&L for substances and mixtures
  • Compliance check for labels
  • Notifications to the C&L Inventory
    • Advice on best option for submitting C&L notifications
    • Submission of notifications to the C&L Inventory
    • Manage groups of manufacturers / importers for C&L notifications
  • Poison Center Notifications (PCN)
    • Advice on PCN requirements
    • UFI generation & validation
    • Dossier preparation and submission
    • Support to fulfill national requirements
  • Advice for managing nanomaterials under CLP
  • Representation to meetings (e.g. EU associations)
  • Support to determine the company size according to Commission Recommendation 2003/361/EC (relevant when claiming reduced fees for SMEs under CLP)

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11 May 2021

CLP & In Vitro Diagnostic (IVD)

What applies?

CLP excludes from its scope in vitro diagnostic medical devices (IVDs) in finished form (Article 1(5)(d)). Does this mean that a hazard label according to CLP doesn’t have to be prepared for a product registered as IVD? Not exactly. The sector legislation (Directive 98/79/EC, replaced by Regulation (EU) 2017/746 from May 2022), provides that CLP labelling requirements fully apply and only in special cases hazard label elements can be omitted....
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26 Apr 2021

New SDS Requirements

Starting 2021

Regulation (EU) 2020/878 updated REACH Annex II, which sets the requirements for the compilation of the Safety Data Sheets (SDS) within EEA. The main purpose of the update was to include in the SDS information on nanomaterials and on hazards related to endocrine disrupting properties, as well as to implement the requirements of the latest GHS version into the EU legislation. Newly prepared SDS have to comply with the regulation starting January 2021. SDS prepared before January 2021 have to be updated by 2023. ...
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22 Apr 2021

SCIP for Importers

Data Gaps & Batteries Case

According to Art 9(1)(i) of the Directive 2008/98/EC (Waste Framework Directive), starting 5 January 2021 articles containing SVHC above 01,%w/w need to be notified to the ECHA SCIP database before they are placed on the market. The SCIP notification needs to be done by all actors placing such articles on the market e.g. EU producers or assemblers, EU importers and EU distributors. For importers it is difficult to collect the necessary information....
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