By Dr. Charlotte Blackburn, Regulatory Specialist
At the 31st meeting of the Competent Authorities for REACH and CLP (CARACAL), held on 18th September 2019, the proposed amendments to Annex VIII to CLP were agreed, which – amongst other changes – pushes back the first Poison Centres compliance deadline for mixtures intended for consumer use by one year, bringing it in line with the deadline for professional use mixtures.
Janice Robinson, Director Product Regulations for CEPE and chair of DUCC, who has been working on Annex VIII matters, informed us:
“The proposed first amendment of Annex VIII to CLP, which harmonises the information that will be made available to EU Member State Poison Centres, is now being adopted, and it is expected that the amended regulation will be published in the Official Journal and enter into force in Q4 2019. Importantly, this amendment includes a postponement of the first compliance deadline, meaning that importers and downstream users placing on the market mixtures for consumer use will now need to comply with the Annex requirements from 1st January 2021, which replaces and supersedes the original deadline of 1st January 2020.”
With many workability issues and ambiguities still unresolved and under discussion, this postponement will come as welcome news for many companies, and will grant an additional year to ensure compliance with the new harmonised requirements.
What Are The New Deadlines For Poison Centre Notifications?
The key deadlines for duty holders placing mixtures on the market are now set to be:
- 1st January 2021 – Mixtures for Consumer Use
- 1st January 2021 – Mixtures for Professional Use
- 1st January 2024 – Mixtures for Industrial Use
Which Poison Centre Notification Deadlines Do You Need To Comply With?
To determine which of the three deadlines you must comply with, you will need to identify the final use of the product before it reaches its end-of-life stage, therefore it is important to have an understanding of your full supply chain, and how and where your mixtures end up on the market.
There has been no change to the transition period, and therefore if you have placed a product on the market and have notified Member States in accordance with current national legislation, then you will have until 1st January 2025 to comply with Annex VIII requirements – unless the product changes.
Other Poison Centre Resources:
- Poison Centre Notification Checklist
- Poison Centres: A “How To” Guide For Annex VIII Compliance [White Paper]
Poison Centres: What You Need To Know
For more information about Poison Centres, check out our dedicated Poison Centres Homepage, where you can find the latest resources, including White Papers, Webinars and FAQs to help you understand your obligations under Annex VIII. You can also learn more about our expert tools and services which can help you meet your compliance requirements.
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