The new Annex VIII to the CLP was designed to harmonize the format
and content of the notification requirements and correct the inconsistencies
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that emerged under the previous system...
supplier of a MiM changes its formula, then its UFI will change.
This means that any product containing the modified MiM will
need to be re-notified and a new UFI must be generated for the
overall product.
Another new feature of Annex VIII is the European product
categorization system (EuPCS) which is used to describe the intended
use of a mixture that is being notified. The purpose of the
EuPCS is to support the reporting and monitoring of poisoning
incidents in the EU as well as help to identify product risks for
specific mixture categories when other information
is unavailable. Some examples of product categories
include “aerosol paints and coatings” and “floor
cleaning products.”
How to prepare for the upcoming deadlines
ECHA has some helpful resources available for those
who want to learn more about Annex VIII to CLP.
Version 1.0 of the Guidance on Harmonized Information
Relating to Emergency Health Response is currently
available on the Guidance on CLP section of ECHA’s
website (echa.europa.eu). If you have obligations under
Annex VIII to CLP, this guidance document provides
valuable information about the requirement to notify
hazardous mixtures to the Member States’ appointed
bodies. We can expect to see an updated version of
this document this year that will include clarification
about the obligations of distributors placing hazardous
mixtures on the market in the EU.
Additionally, the ECHA submission portal web
page provides some key documents, including a guide
to dossier preparation and submission as well as an
overview of how Member States have implemented Annex VIII
requirements so far.
Notifying now rather than waiting until the deadline can be
beneficial for multiple reasons. Currently, most member states are
not charging fees for notification. It is unclear how the fee structure
will change in the future, so submitting notifications now is
a good way to save on this anticipated cost. Companies that notify
member states before the 2020 deadline may take advantage of
the transition period, which means that there is no
obligation to comply with new Annex VIII requirements
until Jan. 1, 2025. Additionally, there is
a moral obligation for companies to submit the
relevant information so that in case of an exposure
incident, emergency responders can give appropriate
advice.
Some key factors to consider in preparation
for the upcoming deadlines include determining
which products require notification, to which
Member States a submission is needed, and by
when must the notifications be completed. EuPCS
categories should be determined for each product;
UFI codes must be generated and added to product
labels and notification dossiers will need to be
prepared. Once your hazardous mixtures have been
notified, you will be able to rest easy knowing that
emergency responders have the information they
need to respond to any potential incident involving
one of your products.
For more information about EU poison center
notification, contact us at Nexreg Compliance by
visiting nexreg.com. Spray