On 10th November, A.I.S.E. submitted its response to the Open Public Consultation conducted by the Commission on the Targeted Revision of Regulation (EC) No 1272/2008 on the classification labelling and packaging of substances and mixtures (CLP Regulation).

This public consultation will fuel Commission's work to revise CLP of the Commission, as pledged by the its ‘Chemicals Strategy for Sustainability’.

Questionnaire consists of two sections - first section targeting consumers with general question; the second section dedicated to technical points of the CLP Regulation

Along with our contribution to the Open Public Consultation on the revision of CLP, here are our key messages, further developed in A.I.S.E.’s earlier input to the consultation on Inception Impact Assessment.

• A robust and consistent regulatory framework is vital to ensure a competitive and successful EU industry. Thus, we urge the Commission not to rush decision-making processes for the revision of CLP, or any other legislation.
• Any amendments to the CLP regulation, whether fundamental revisions or periodic delegated acts, must be carried out with sufficient and realistic transitional periods. We believe that the notion of ‘first placing on the market’ is a regrettable shortage of the CLP regulation. It would allow for industry to be continuously compliant with newly-implemented amendments without them leading to scrap off stocks of products.
• The introduction of new hazard classes should be discussed at UN GHS level first to maintain global coherence. New hazard classes and relevant criteria should be motivated by science and decided after a sound scientific demonstration has been obtained.
• Animal testing should be replaced, reduced and refined. Better yet, animal testing should be avoided to the maximum extent possible by promoting alternative testing methods. However, improvements are still ahead as alternative methods currently conclude to 70% of false positives for classification of chemicals.
• Labels must be simplified to favour consumers’ understanding. Simplification of labels can be achieved by Digital tools as elaborated in A.I.S.E.’s input to the Digitalization roadmap.