The sixth EU-wide Enforcement Forum Project (REF-6) found significant non-compliances in hazardous mixture classification and labeling in 2019. The most common mixtures checked were washing and cleaning products; biocidal products; coatings, paints, thinners and paint removers; adhesives and sealants; room fragrances and air freshener products – these are known to commonly contain hazardous ingredients.
Altogether, inspectors in 29 countries checked 3 391 mixtures and inspected 1 620 companies (manufacturers, importers, downstream users and distributors).
The project also looked at exemptions from labeling and packaging requirements, harmonized classification, biocides obligations and specific rules for liquid laundry detergent capsules.
REF-6 Emphasizes CLP Regulation
The REF-6 project is chartered with checking compliance with and raising awareness of a variety of legal provisions under the CLP Regulation, the most relevant of which were Articles 4, 17, 29, 35 and 37 of CLP, as well as Article 31 of REACH and Articles 17 and 69 of BPR.
Chemical products used by consumers are mixtures of different substances. To make sure that consumers can use them safely, information on safe use is passed onto them on labels on products that communicate the hazards and inform how to use them safely. Thus the main scope of the REF-6 project is to ensure compliance of the classification and labeling of chemical mixtures.
To prepare the correct information on safe use, the mixture must first be classified to identify hazardous properties and on the basis of such hazard classification an appropriate CLP label is prepared.
Main Findings Highlight Non-Compliances
The main findings of the project were:
- 43 %of all reported companies were found to have at least one non-compliance and 44 % of reported mixtures were non-compliant in some way.
- 17 %of reported mixtures were using an incorrect classification, which may result in incorrect labeling on the mixtures, and thereby incorrect safe use advice.
- For certain substances that have hazards of highest concern (carcinogenicity, mutagenicity, reproductive toxicity and respiratory sensitizers), classification and labeling is harmonized throughout the EU to ensure adequate risk management. For 9 %of those substances checked in the project, the required harmonized classification and labeling were not applied.
- 33 %of reported mixtures had incorrect labeling.
- 33 %of the checked safety data sheets were non-compliant with the requirements checked in the project.
- Inspectors checked the requirements for packaging and labeling liquid laundry detergent capsules (LLDCs). The most significant finding is that for 22 %of the checked LLDCs, the closure of the outer packaging did not maintain its functionality when repeatedly opened and closed during the life span of the packaging.
- For checked biocidal products, around 7 %of them lacked either valid authorization according to the Biocidal Products Regulation (BPR) or to national legislation during the transitional period. For 17 % of the biocides, labels were non-compliant.
Manufacturers, importers and downstream users have to put more effort into deriving the right classification for mixtures and communicating it down the supply chain. This will prevent incorrect information being disseminated in safety data sheets and on labels. Industry should also work on improving the quality of safety data sheets, which will in turn lead to improved information flowing through the supply chain.
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