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Regulatory
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Trace One
Annex VIII: what does that entail?
According to article 45 of CLP Regulation, importers and downstream users who place hazardous mixtures in the market should submit relevant information in the event of emergency health response to designated appointed bodies.
Annex VIII of CLP, added by 2017/542 Regulation, has the aim to harmonize, in terms of format and content, the information relating to emergency health responses in the EU market.
Last November 13th 2020, the European Commission published on the Official Journal the regulations 2020/1677 and 2020/1676 regarding resp. the new consolidated text of Annex VIII and the amendment to CLP Article 25 concerning bespoke paints.
More clarifications regarding the solutions:
The changes confirmed by Regulation 2020/1677, in line with what has already been reported in the previous provisional texts and consisting of both sector-specific and cross-sector solutions, mainly concern:
- The possibility to enter information regarding group of raw materials coming from different suppliers by grouping them into an ICG (Interchangeable Component Group), provided that all the grouped raw materials are toxicologically and technologically similar
- Deviation from the standard compositional notification criteria for fuels (reported in Table 3, Part B), for which it will be possible to transmit the composition reported in the Safety Data Sheet and for products belonging to the cement, gypsum and concrete sectors, for which it will be possible to refer to standardized formulas, listed in Part D of the Regulation
Regarding the paints sector, Regulation 2020/1676 focuses on bespoke paints by modifying Article 25 of the CLP Regulation, exempting the final paint from the notification obligation but prescribing the need to report on the label of the final mixture the UFI of the single component mixtures subject to the notification obligation if present above 0.1% or the UFI plus concentration if present above 5%.
The changes made by Regulation 2020/1677 have already been technically implemented in the official format, released only on October 28th by ECHA. Trace One is currently working to provide a solution that allows the generation of notifications according to the format accepted by the official PCN portal.
For more information about the next release and the new features that will be available in the software, we recommend registering for the webinar at the following link:
To view the Regulations 2020/1676 and 2020/1677 (Annex VIII to the CLP) you can use the following links:
Newsletter 138