About chemicals with non-CLP designations

Some chemicals have been assigned non-CLP designations which may still affect the CLP label, and also the Safety Data Sheet (SDS).  Most of these non-CLP designations derive from the REACH regulation, and one is derived by the EU and individual member states (chemicals with occupational exposure limits).

Nano materials have been included because they are currently regulated in some EU countries, notably France, and this may lead to them being regulated through the whole of the EU.  The IARC Carcinogen List has also been included in this section for reference, as it can be important for some end users to know whether e.g. a mixture contains any substances included on this list.

The non-CLP designations for chemicals include:

• Substances of Very High Concern, SVHCs (generated by the EU)
• Authorised Chemicals (generated by the EU)
• Restricted Chemicals (generated by the EU)
• Chemicals with Workplace Exposure Limits, WELs (generated by the EU and individual EU member states)
• Persistent Bioaccumulative and Toxic substances, PBT (as defined by the EU)
• very Persistent, very Bioaccumulative substances, vPvB (as defined by the EU)
• Ozone depleting chemicals
• IARC’s Carcinogen List

Some of these designations are technical, that is based on specific hazardous properties which can be tested for, or which are known to produce risk to health and/or the environment.

Other designations are political, that is they cannot necessarily be tested for, but are considered to be so hazardous that they need to be controlled or banned.

The “technical” designations include IARC Carcinogens (although these can sometimes be political as well), Chemicals with WELs, and PBT and vPvB substances.

The “political” designations are SVHCs, Authorised Chemicals and Restricted Chemicals, where decisions have been taken to monitor or control the use of chemicals over and above normal CLP and REACH practices.

Prior Informed Consent substances have been included on this list for completeness, because they require notification to ECHA before import/export.