The Classification, Labelling and Packaging (CLP) Regulation 1272 was introduced in 2008 to ensure there is a high level of protection of health and the environment, and allow free movement of substances, mixtures and articles in the EU. Article 45 of the CLP Regulation requires companies placing hazardous mixtures on the market to provide information about their products.

In 2017, Annex VIII was added to the CLP Regulation. The new annex introduced one central poison centre – the ECHA (European Chemicals Agency) submission portal – to replace the existing individual country centres. Once a product is uploaded to the portal, the information is available throughout Europe.

How CLP affects vaping

Article 45 requires EU vaping companies (‘EU importers and downstream users’) to report their mixtures, ‘..placed on the market that are classified for human health..’.

What is required?

Full guidance is available on www.poisoncentres.echa.europa.eu/steps-for-industry

Principal elements include:
• provide the full chemical composition of the mixture – this means both the hazardous and non-hazardous components.
• label your product with a unique formula identifier (UFI) – the UFI allows poison centres to rapidly identify the product
• assign a product category according to the European Product Categorisation System (EuPCS).

Can I do this myself?

In short yes. It is worth noting that considerable technical expertise is required to compile a notification due to the technical information on the chemicals in each product.

How soon do I have to do this?

The deadline for submitting notifications is 1 January 2021.

How can ADACT help?

Due to the complexity of the process, many customers have asked us for help. We are able to register products with our trusted guarantee that it is done correctly and on time. As part of the registration process, we generate a Unique Formulation Identification (UFI) code. The codes must be clearly printed on corresponding product packaging to meet compliance requirements.

Poisons Centres and the UK

The current regulations for the UK require vaping companies to submit Safety Data Sheets (SDS) to the UK Poison Centre by email only – a digital service is planned for the future. Email sds@npis.org. Note: SDS must be REACH Regulation EC No 1907/1148 Annex11,2019 compliant.

Poisons Centres and Sweden

In addition to the standard ECHA Poisons Centres portal, Sweden now requires companies to notify The Public Heath Agency of Sweden via the EU Common Entry Gate (EUCG). Read more about this here.

Comply on time and help save lives: https://youtu.be/-7f88r6Dk0Y

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Companies around the world have trusted ADACT with their regulatory compliance.

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  • All our testing is completed in our own state of the art ISO 17025 accredited laboratory, providing results you can trust and rely on.
  • Choose an agency with proven results who is dedicated to your success. We have immense experience in providing compliance with over 1,500,000 TPD notifications since May 2016.

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