Converting GHS classifications to CLP
A substance or mixture which has been classified for GHS outside the EU is likely to be relatively easy to convert to CLP, as long as it is not a substance which holds a Harmonised Classification in the non-EU country.
You can also download this flowchart as a pdf: Routes for converting a GHS classification into a CLP classification.
If you have only a GHS label, there will be no data on the label, but you should have the H statements, signal word and pictograms, and you may be able to infer the classification from this information. If you can get hold of a full GHS SDS, there will be the classification, labelling information, and also (with luck) some usable data in the relevant sections of the SDS.
If the product is a substance with an EU Harmonised Classification, that takes precedence over any other information.
When converting a GHS classification into a CLP classification on the basis of its hazards, there are three steps:
- list all of the GHS classifications which apply to the product
- remove any GHS hazards not used in the EU
- add in any GHS hazards used in the EU and not used in the other jurisdiction
Listing all applicable GHS classifications
Normally, this will simply be the GHS classifications on the label or SDS. However, if the product is a substance which holds a non-EU harmonised classification, or you have any doubts about the validity of the original classification, you may want to compare the supplier’s GHS classification with published substance classifications in the EU, and choose those which you think are most relevant: Classification comparison form.
Removing any GHS hazards not used in the EU
The EU does not use every single GHS hazard, for example some low-level toxicity hazards and the lowest level of flammability hazard are not included; and several newer classifications have not been adopted yet.
Overall, 9 low-level hazards have not been adopted from GHS into CLP, and are unlikely to be; 5 new hazards in GHS revision 6 have not been adopted yet into CLP (and we don’t know whether they will be yet); 1 hazard has a slightly different H code in CLP compared to GHS; there are 4 re-arranged hazards (same principle but written differently) and 1 new hazard in GHS Revision 7, and 1 new hazard, which have not been adopted yet into CLP (and we don’t know whether they will be yet). These hazards are:
You can also download this list as a pdf here: GHS classifications and H statements not in CLP GHS Rev 7.
Add in any GHS hazards used in the EU and not used in the other jurisdiction
First, you need to check whether the GHS jurisdiction has adopted all of the GHS hazards, which can be done by looking on the UNECE website at https://www.unece.org/trans/danger/publi/ghs/implementation_e.html .
If the GHS jurisdiction covers all GHS hazards, you don’t need to do anything else.
However, if the GHS jurisdiction does not cover all GHS hazards covered by CLP, you need to review the SDS (or other sources of data) to see if you are able to classify the hazards from first principles based on that data, using the methods at https://ttenvironmenta.wpengine.com/knowledgebase_category/first-principles-clp-classification/ .
One example of this is the USA, where OSHA has adopted physical and health GHS hazards, but USEPA has not yet adopted environmental GHS hazards, so they are considered voluntary in the USA at the time of writing. However, the GHS Safety Data Sheet (SDS) includes environmental data in Section 12, Ecological information, so there may be relevant data on e.g. aquatic toxicity hazards which will allow you to classify these hazards for CLP.
In the event that there is no data on hazards relevant to CLP, you can either try to read-across to related substances or mixtures; classify on a precautionary basis, based on expert judgement (a toxicologist or eco-toxicologist may be needed for this step); or have the product tested to provide information on those hazards (avoiding animal tests where possible).
Once you have gone through these steps, your product should now be classified for CLP as well as for GHS, and the next step is to add the labelling information (signal word, pictograms, P statements, EUH statements etc), see https://ttenvironmenta.wpengine.com/clp-knowledgebase/generating-clp-label-information/ .