Over 40% of hazardous chemical mixtures found to be CLP non-compliant by EU-wide ECHA FORUM enforcement project.

ECHA has recently published a report detailing the findings of its sixth EU-wide enforcement forum project (REF-6), focussed on hazardous mixture classification and labelling compliance.

3391 mixtures from 1620 companies, including producers, importers, distributors and downstream users, across 29 EU countries were inspected by Member State National enforcement authority (MS NEA).

Mandatory checks on classification and labelling of hazardous mixtures were conducted by all participating MS NEAs. Mixtures classified via bridging principles, cases of extreme pH, and mixtures without whole-mixture test data, were all exempt from inspection under the scope of this project.

MS NEAs also had the option to inspect biocides, liquid laundry detergent capsules (LLDCs), mixtures with harmonised classifications, and mixtures exempt from labelling & packaging obligations.

Significant levels of non-compliance were reported:
ECHA has stressed the importance of correct classification of mixtures by duty holders, improved quality in SDS and labelling, and better communication down the supply chain, with the aims of reducing inconsistencies and non-compliance in the interest of user safety. To track improvements in these areas, a repeat enforcement project in a few years’ time has been recommended.

• 45% of inspected companies had at least one non-compliance

• 44% of mixtures non-complaint

• A third (33%) of SDS has issues/shortcomings/deficiencies

• 1 in 5 products had inconsistencies between their label and SDS section 2.2

• 17% of reported mixtures incorrectly classified.

• 1 in 5 (22%) LLDCs failed lid closure life-span durability tests

• 17% of biocide labels non-complaint

• 7% of biocides lacked valid authorisation and therefore marketed illegally.

• 9% of harmonised CMRs non-compliant

References:

https://echa.europa.eu/documents/10162/13577/ref-6_project_report_en.pdf/

Author:

Sam Allan, Associate Hazard Communication Consultant, Yordas Group