Classification, Labelling and Packaging of Chemicals in Europe

However under CLP the same product will now be classified and labelled as such:

Rust remover containing phosphoric acid under CLP

Hazard Class and Category codes: Skin Corr. 1B, Met. Corr. 1
Signal Word: DANGER

Hazard Statements:
H290 – May be corrosive to metals.
H314 – Causes severe skin burns and eye damage.

Precautionary Statements:
P234 – Keep only in original container.
P260 – Do not breathe mists.
P264 – Wash hands thoroughly after handling.
P280 – Wear protective gloves/clothing/eye/face protection.
P301+P330+P331 – IF SWALLOWED: Rinse mouth. Do NOT induce vomiting.
P303+P361+P353 – IF ON SKIN: Take off immediately all contaminated clothing. Rinse skin with water/shower.
P304+P340 - IF INHALED: Remove person to fresh air and keep comfortable for breathing.
P305+P351+P338 – IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing.
P310 – Immediately call a POISON CENTRE/doctor…manufacturer specifies
P321 – Specific treatment (see…on this label)
P363 – wash contaminated clothing before reuse
P390 – Absorb spillage to prevent material damage.
P406 – Store in a corrosive resistant container with resistant liner.

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What types of products are affected by CLP?

CLP applies to all substances and mixtures imported, manufactured or placed on the market within the EEA unless otherwise exempted. Examples of products regulated under CLP are paints, glues, spray paints and pesticides.

There are exemptions to the regulation for the following materials in their finished state only:

• Articles (e.g., batteries)
• Food and feeding stuffs
• Cosmetics
• Medical devices
• Medicinal products

To determine if your product is regulated under CLP we recommend you take the following steps:

• Contact the manufacturer and ask if the product is regulated under DPD or CLP.
• Check the Material Safety Data Sheet (MSDS) or Safety Data Sheet (SDS) to determine if there are DPD classifications on it. If you do not have an MSDS or SDS for the product, the manufacturer or your supplier should have the document available. See the Hazardous Materials Identification Guide.

When does CLP come into force?

There was a phased transitional period which allowed time to change over from the existing rules. Many of these dates have passed, or are passing soon. Substances must be classified and labelled in accordance with CLP by December 1, 2010; or by December 2012 if already on the market. Mixtures must be classified and labelled in accordance with CLP by June 1, 2015; or by June 1, 2017, if already on the market.

Does CLP apply to sellers?

Yes, as a seller it is your responsibility that your products are CLP compliant.

What CLP regulated products are prohibited for Fulfilment by Amazon?

Products which bear any of the following CLP hazard statements are prohibited for Fulfilment by Amazon:

Risk Phrases prohibited in FBA
EUH001	Explosive when dry
EUH006	Explosive with or without contact with air
EUH014	Reacts violently with water
EUH018	In use may form flammable/explosive vapour-air mixture
EUH019	May form explosive peroxides
EUH029	Contact with water liberates toxic gas
EUH031	Contact with acids liberates toxic gas
EUH032	Contact with acids liberates very toxic gas
EUH044	Risk of explosion if heated under confinement
EUH059	Hazardous to the ozone layer
H200	Unstable explosive
H201	Explosive; mass explosion hazard
H202	Explosive; severe projection hazard
H203	Explosive; fire, blast or projection hazard
H240	Heating may cause an explosion
H241	Heating may cause a fire or explosion
H250	Catches fire spontaneously if exposed to air
H251	Self-heating; may catch fire
H252	Self-heating in large quantities; may catch fire
H260	In contact with water releases flammable gases which may ignite spontaneously
H261	In contact with water releases flammable gas
H300	Fatal if swallowed
H301	Toxic if swallowed
H304	May be fatal if swallowed and enters airways
H310	Fatal in contact with skin
H311	Toxic in contact with skin
H330	Fatal if inhaled
H331	Toxic if inhaled
H340	May cause genetic defects
H341	Suspected of causing genetic defects
H350	May cause cancer
H351	Suspected of causing cancer
H360	May damage fertility or the unborn child
H361	Suspected of damaging fertility or the unborn child
H362	May cause harm to breast-fed children
H370	Causes damage to organs
H371	May cause damage to organs
H372	Causes damage to organs through prolonged or repeated exposure
H373	May cause damage to organs through prolonged or repeated exposure
P222	Do not allow contact with air
P223	Keep away from any possible contact with water, because of violent reaction and possible flash fire
P230	Keep wetted with (insert manufacturer specification)
P231	Handle under inert gas
P406	Store in a corrosive resistant (insert manufacturer specification) container with a resistant inner liner
P407	Maintain air gap between stacks/pallets

Are there any products Amazon previously accepted, but under CLP are now prohibited for Fulfilment by Amazon?

Yes, there are six DPD codes transitioning to CLP which are not accepted in Fulfilment by Amazon: DPD codes R18, R31, R32, R33, R64, and R65 will transition to CLP codes EUH018, EUH031, EUH032, H373, H362, and H304 which are prohibited in FBA (see affected risk phrases above). Please ensure you immediately discontinue sending these products into FBA.

What are Amazon’s additional requirements for sellers in relation to CLP?

It is seller’s responsibility to provide accurate and complete product information, including warning messages in the format we require. In order to add applicable warnings to your product listings, you should do the following:

Determine if the CLP Regulation (EC) No 1272/2008 on the classification, labelling and packaging of substances and mixtures, or simply CLP applies to your product. This may inter alia be verified by contacting the manufacturer or checking the product labelling.

If your products are regulated under CLP, verify that your products are eligible for sale on Amazon. If you want to use FBA, provide us with the completed ‘Product Compliance’ template that is available here.

What happens if I send products to Amazon’s fulfilment centres which are prohibited in FBA?

You must not ship prohibited products into FBA. Amazon may at your cost and without compensation to you dispose of units regulated under CLP and prohibited for FBA.

Where can I find additional information?

We encourage you to visit the European Chemicals Agency (ECHA) for more information on CLP.

• ECHA: http://echa.europa.eu/regulations/clp

Product Compliance File

The Product Compliance template contains 5 tabs:

• Instructions: This tab will give you some useful information about how to use the EU Compliance data feed template.
• Data Definitions: This tab will identify necessary information and format.
• Template: This is the template that you shall complete.
• Example: This tab provides an example of how to complete the information.
• Valid values: This tab contains the full list of acceptable values. You will be required to enter the full wording.

Please note that out of the 586 acceptable values, 41 values require additional information that may vary from one product to the other.

Example:

Let us take the safety phrase P261 that corresponds to ‘Avoid breathing …’: You will be required to enter an additional value like ‘gas’, in order to complete the phrase. If you miss entering the value, your upload will fail.

Once completed, upload your Product Compliance template in Seller Central.

In addition, when using FBA, you must submit for CLP regulated products the MSDS/SDS or an MSDS exemption sheet as applicable to Amazon. You can upload the MSDS or SDS using this link.

The upload takes 3 steps:

1. List all ASINs above which are concerned by the Material Safety Data Sheet (MSDS) or Safety Data Sheet (SDS) (up to 10).
2. Choose the respective EU Marketplace.
3. Attach your SDS using the Browse button and then click Continue. If there is more than one SDS for a product, all SDS have to be grouped in a single .zip file before uploading.

Please repeat this operation as many times as necessary (once per SDS).