CRD issues advice for Authorisation Holders and Parallel Trade Permit Holders on Classification, Labelling and Packaging (CLP) of plant protection product
Action is required on behalf of Authorisation Holders and Parallel Trade Permit Holders in relation to the Classification, Labelling and Packaging (CLP) Regulation (EC 1272/2008) which is replacing the Chemicals (Hazard Information and Packaging for Supply) Regulations (CHIP). The CHIP-CLP-Guidance has been amended accordingly at paras. 9, 13 and 15.
What is changing
- In the transitional period prior to 1st June 2015 suppliers must classify products according to CHIP and may continue to label and package according to CHIP. However, they may also choose to classify the product in line with CLP and in such cases label according to CLP.
- From 1st June 2015 onwards suppliers must classify, label and package according to CLP only. The re-labelling and re-packaging of products which are already in the supply chain (‘on the shelves’) on this date may be postponed until 1 June 2017.
What actions do you need to take?
- For existing CHIP classified products – You must notify new CLP classification and labelling details by 1st June 2015 for all your products. Please ensure that you submit the notification using the table in Appendix 2 of the CHIP-CLP-Guidance.
- For new authorisations – We only make full assessments of new CLP classifications in applications for new products, formulation changes and re-registration. To ensure that CRD issue new authorisations after 1st June 2015 with a CLP classification, any such application must now include a classification and labelling proposal according to the CLP Regulation.
- if you are making any other type of application for a CHIP classified product, you may include the new CLP notification at the same time and we will add it (without assessment) in the new Notice of Authorisation subject to there being no adverse changes.
- In either case please use the same tablulated format as detailed above
How do these changes affect Parallel Trade Permits?
- Parallel Trade Permit holders must comply with CHIP/CLP requirements and ensure that that their product is classified and labelled under CLP for stocks entering the supply chain on 1 June 2015. However, as Permit holders cannot classify the product without full details of the formulation, such products must mirror the classification and labelling on the ‘reference product’.
- For CHIP-classified products, Permit Holders must first wait for the change to CLP on the reference product before they can re-label. To allow this label change to be legally made, an Amendment Parallel Trade Permit is attached which allows Permit Holders to amend a CHIP classification and labelling to CLP when the change is actioned for the reference product. All new Parallel Trade Permits will now also include this condition of labelling
For further information on the CLP regulation, or any other regulatory issues, please contact JSC on +44 (0)1423 520245, email@example.com
Published 23rd October 2014
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