CLP Regulation updated with the 21st ATP
The 21st Adaptation to Technical Progress (ATP) of the CLP Regulation lists substances for which the Risk Assessment Committee (RAC) of the European Chemicals Agency (ECHA) has published an opinion. The classification of substances is included or updated in Annex VI. As a result, producers may have to change their product label, or there may be consequences for the authorisation. Producers are expected to keep track of these changes themselves.
The classification of 24 substances has been updated, 11 of which are relevant to plant protection products or biocides. Of the 28 new substances included in the harmonised list, five can be used as active substances in plant protection products.
Holders of existing authorisations are not required to immediately comply with these new harmonised classifications. This gives suppliers the opportunity to modify the labelling and packaging of products in accordance with the new classifications and to sell existing stocks. The transition period for existing labels ends on 1 September 2025.
Application to amend label
If the classification of a substance changes, manufacturers of a product based on such a substance are required to determine whether that new classification affects their product authorisation. They are responsible for this themselves and are expected to take appropriate action if necessary. They may have to change the product label or this could have consequences for the product authorisation. For plant protection products and biocides, this is done by submitting an administrative application to amend the label to the Ctgb or through R4BP (the biocides register of ECHA).