Complying with CLP is not always straightforward and NCEC is frequently contacted for advice by companies trying to understand their obligations. For companies interested in the Spanish market, things have just become a little easier and those struggling to comply with CLP can take heart in the fact that governments are facing challenges implementing CLP as well.
EU member states have taken a variety of approaches in implementing Article 45 of CLP, the requirement for member states to appoint a body to receive product information on hazardous mixtures. These range from the UK’s voluntary submission model, France’s phased submission to Germany’s mandatory submission of all hazardous mixtures. However, some approaches have been more successful than others.
Spain decided on a robust process requiring compulsory submission of product information to the Toxicology Information Service (SIT) for all hazardous products by the 1st of June 2015. The data required includes a toxicological profile of the mixture, the SDS and copies of Spanish product labelling. The volume of submissions was expected to be large, so the SIT introduced an electronic submission process to help streamline submission and a fee for each product submitted to cover the poison centre’s administrative burden.
As predicted, the volume of submissions the SIT received was indeed substantial and implementing the electronic system proved challenging, which has recently forced the Spanish government to partially deregulate the submission of product information. Order Jus / 992/2015, of 29 May introduces a transition period, extending the submission deadline, to allow the SIT to cope with the number of submissions.*
Companies placing hazardous mixtures onto the Spanish market now have until the 1st of January 2016 to register products with certain hazard classes:
Companies then have until the 1st of June 2017 to register any remaining hazardous mixtures not in the hazard classes specified above. There is one important exception, if companies wish to use the Spanish poison centre telephone number on their SDS, they must immediately register their products with the SIT.