CLP Regulations: EU Wants to Change Requirements for Notifications to Poison Centers About Mixtures in Mixtures

The EU plans to simplify the notification requirements for bespoke paints, petroleum products, and building materials like plaster, cement, and concrete, known as mixtures-in-mixtures (MIM) products. Companies in the effected industries had monitored feasibility and called for a simpler set of rules for the products. After studying the matter, the EU decided to comply with this request.

Concretely, two changes are involved. First, bespoke paints (those that are mixed at the point of sale according to customer requirements) are to be treated as a special case and Article 25,
paragraph 8 of the CLP Regulation
modified accordingly. In fact, the requirements for paints are quite individual, and an infinite number of color mixtures exists. Rather than requiring a unique formula indicator (UFI) for each bespoke color, it will be enough to list the UFIs of the individual color components in the order of their concentration on the label, as required in Annex VIII, Part A, Section 5.

Second, Annex VIII, Part B, Sections 3.5–3.8 are to be supplemented. Notifications for petroleum products and building materials like plaster, cement, and concrete products are to be simplified. The concentrations of their components can vary significantly. The model of interchangeable component groups can help here. In the future, not every individual mixture concentration must be considered on its own. Instead, they can be combined into mixture groups and treated as a unit as long as their technical function, the classification of their components in terms of health and physical hazards (hazard classes, categories, and notes), and their toxicological profiles are identical.

The EU first published Regulation 2020/11 and modified Annex VIII of the CLP Regulation, granting companies a delay in notification for hazardous mixtures used by consumers.

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