CLP Challenges for SMEs
CLP Challenges for SMEs
Sylvie Lemoine
Workshop on the safe use of chemicals by SMEs
Introducing A.I.S.E.
Introducing A.I.S.E.
International Association for Soaps, Detergents and
International Association for Soaps, Detergents and
Maintenance Products
Maintenance Products
• Members:
¾ 37 National Associations in 42 countries ¾ 9 direct member companies
• About 900 companies - 60% SMEs - reached primarily via our National Associations Network
• Consumer and Industrial & Institutional (I&I) markets
¾ Range of products with different functions ¾ Used in every home, every day
- CLP is complex and significantly different from DPD
- More mixtures classified, more severely, more information on labels
- Even large, well-prepared, well-resourced companies are struggling to meet the 1 June 2015 deadline. This is exacerbated for SMEs
Preparing for CLP in A.I.S.E.
Preparing for CLP in A.I.S.E.
• Sector well prepared, since 2007
• Awareness raising / communication to member SMEs
• Sector guidance note (A.I.S.E. + National Associations)
• Trainings, workshops
• Development of an industry classification network (2009-2013)
• Liaison with substance suppliers sector groups
• Customer/consumer education: leaflets
Where do SMEs stand right now?
Where do SMEs stand right now?
July 2014 survey July 2014 survey
(15 SME companies, 2 multinationals, 7 countries) (15 SME companies, 2 multinationals, 7 countries)
• All companies are aware of their CLP obligations
• Most companies in our sector feel well prepared and value support provided by
– ECHA documents
– Trade associations, e.g. training, workshops, information notes – Consultants occasionally
– External events
– Connections with peers
• Preparatory status
• It takes about one year to go through the full CLP process
15/15 have started to reclassify their products 10/15 have started to relabel their products
What are the main challenges SMEs
What are the main challenges SMEs
are currently facing ?
are currently facing ?
July 2014 survey (15 SME companies) July 2014 survey (15 SME companies) • Timing, resources and costs
• Dependence on suppliers for classification • Change and validation of IT tools
• Legal certainty: interpretation not always harmonised across MS • In some cases, need to reformulate
• In some cases, changes to packaging: child resistant closures, TWD, new packaging requirements in the pipeline for soluble unit doses
Challenges SMEs are currently facing
Challenges SMEs are currently facing
July 2014 survey (15 SME companies) July 2014 survey (15 SME companies)
• Raw material (substance/mixture) data: inconsistencies, data lacking, not available or coming too late, updates
• Lower generic concentration limits (vs DPD): more « severe » labelling
• Data accepted for classification: test data vs calculation, bridging principles, weight-of-evidence
• New classification rules, e.g. 2nd ATP to CLP
• Safety Data Sheets update
• Downstream consequences e.g. biocidal products
7
What are the main challenges SMEs are
What are the main challenges SMEs are
currently facing ?
currently facing ?
July 2014 survey (15 SME companies) July 2014 survey (15 SME companies)
• Size of labels
• Multi-lingual labels: fold-out labels
• Selection of P-statements (+ translation issue, 5th ATP changes, P501 unclear)
• Translations
• Chemical names: INCI vs other names
• Printing in 3 colours, incl carton box: costs!
• Labelling of different layers: Transport vs supply • Printing on soluble film (unit dose products)? • Obsolete label stocks
LABELLING
What is A.I.S.E. doing?
What is A.I.S.E. doing?
Building on new CLP features for
Building on new CLP features for
appropriate and user
appropriate and user
-
-
relevant C&L
relevant C&L
Label should reflect actual effects on man
•Mixture data sharing for
products of similar composition:
bridging principles
•In-vitro programme
What is A.I.S.E. doing?
What is A.I.S.E. doing?
Exploring practical solutions
Exploring practical solutions
750 mL pack, 3 languages, fold-out
Product identifier, pictograms, signal P-statements
Cost savings : €100 million
(A.I.S.E. sector)
How can authorities and other
How can authorities and other
stakeholders help SMEs?
stakeholders help SMEs?
Pragmatic solutions in line with the CLP
Pragmatic solutions in line with the CLP
objectives
objectives
• Help prioritise information for multilingual labels, consider fold-out
labels
• Allow INCI names in product identifier (Article 18(3)): used under Detergents Regulation, no translation needed, shorter
How can SMEs successfully pass
How can SMEs successfully pass
the 1 June 2015 deadline ?
the 1 June 2015 deadline ?
1. Good preparation
– Training
– Plan (timing and investments), start on time, organise internally across departments (incl marketing and higher management) – Check product portfolio, gather substance data
– Seek support and expertise
2. Good IT tool(s)
3. Good communication with suppliers and customers
•Safety Data Sheets are a good tool for safety communication (workplace): let’s build on it
•Labels should reflect actual product attributes: the label must
contain useful, actionable information and help convey differentiation of hazard levels between different products
•Consumer/user education campaigns are needed, without
‘stigmatising’ chemicals
•Longer-term: smarter labels for consumers? Engage in a
multi-stakeholder dialogue about WHAT and HOW to communicate to
