Overall scope of CLP
GHS, and therefore CLP, applies to:
- substances (pure, and with impurities affecting their classification)
- substances in dilute solution
GHS, and CLP, does not generally apply to articles, except explosive articles and articles producing a pyrotechnic effect.
CLP only applies to chemicals used for general purposes. Chemicals used specifically as medicines, cosmetics, food, veterinary medicines etc, and waste chemicals, are covered by other regulations. Some chemicals, such as biocides, use CLP classification, but have their own specific labelling requirements requiring extra information. See https://ttenvironmenta.wpengine.com/clp-knowledgebase/products-not-covered-by-clp/ .
The CLP Regulation does not cover every possible hazard from chemicals, for example asphyxiation hazards from non-toxic gases, or the risk of dust explosions from organic powders. See https://ttenvironmenta.wpengine.com/clp-knowledgebase/hazards-not-included-in-clp/ .
For details of individual hazard groups covered by CLP, see:
Unlike other classification systems, CLP also includes a requirement to notify the chemical classification of each substance made or imported into the EU to a central inventory held at ECHA, see: https://ttenvironmenta.wpengine.com/knowledgebase_category/c-and-l-inventory-notification/ .
In theory, this is to enable companies to compare classifications, and come to an agreement about what they should be, although the requirement to give tonnage band information could lead a cynic to suggest that it is acting as an extension to the REACH system to enable the authorities to estimate the type and quantity of chemical movements into the EU, with a view to some form of centralised control.
However, the system still needs to be complied with when dealing with the EU, and this is covered in a separate category of the knowledgebase,