Harmonised Classifications under CLP

The GHS standard does not contain any mandatory chemical classifications, unlike the Transport system which uses the Dangerous Goods List as the starting point for classification.

This means that individual jurisdictions are free to classify chemicals how they like (within reason), and there can be significant differences in mandatory classifications for supply between countries.

The EU has adopted the list of mandatory classifications from CHIP into CLP.  Under CHIP, this was known as the Approved Supply List, and under CLP, it is the Harmonised Classifications (presumably so called because they have been “harmonised” by agreement in the various member countries)

Harmonised Classifications are available from three sources:

• the CLP Regulation and its Adaptations to Technical Progress (ATPs) at https://echa.europa.eu/regulations/clp/legislation
• online in the Classification and Labelling Inventory (CLI) at https://echa.europa.eu/information-on-chemicals/cl-inventory-database 
• in the Harmonised Classification spreadsheet, current version to 10th ATP, 5th May 2017, see: https://ttenvironmenta.wpengine.com/clp-knowledgebase/harmonised-classifications-list/ )

There are some things to watch out for with Harmonised Classifications:

• they do not include P statements, so you will need to generate these yourself
• they may be partial rather than full classifications, and you will need to research this extra information and decide whether it is valid
• for new Harmonised Classifications under CLP, a very limited range of hazards will be included

For more information on these issues, see: https://ttenvironmenta.wpengine.com/clp-knowledgebase/scope-of-clp-harmonised-classifications/ .

Where a substance holds a Harmonised Classification in the EU, and you receive a GHS label or SDS from outside the EU, you need to be aware that the classification from outside the EU may be different, either because the other jurisdiction may not have the substance on its own version of Harmonised Classifications, or because it is Harmonised, but the classification is different to the one required in Europe.  For example, toluene is classified in the EU as a Category 2 reproductive toxicant, whereas in the Australian version of GHS, it is a Category 1 reproductive toxicant.