Question: Information on article 45 of CLP
Dear Sir/ Madame,
Following your e-mail dated 06/02/2017, we would like to apologise for the delay and inform you on the following:
- The General Chemical State Laboratory of Greece, Directorate of Energy, Industrial and Chemical Products, where you have addressed your e-mail, is the national competent authority for the Regulations 1907/2006/EC (REACH) and 1272/2008/EC (CLP) and responsible according to art. 45, §1 of CLP « for receiving information relevant, in particular, for formulating preventative and curative measures, in particular in the event of emergency health response, from importers and downstream users placing mixtures on the market… classified as hazardous on the basis of their health or physical effects» regardless the quantity of the product and its final use. The National HelpDesk for REACH, CLP and BPR operates within the Directorate of Energy, Industrial and Chemical Products.
- In order to comply with art. 45 of CLP, you have to register your products that are placed on the Greek market in the National Register of Chemical Products (NRCP), following the guidelines described in the following link http://www.gcsl.gr/index.asp?a_id=310&txt=y&show_sub=1 . Registration in the NRCP can be performed by any importer or downstream user responsible for placing the product on the market, who is established within EU. On the product’s label, though, the actor responsible for providing information about the composition of the product should be mentioned, according to art. 17 of Reg. 1272/2008/EC and this data should also be registered in the NRCP. For already existing product registrations, any changes in the composition of the product, the classification of the product, the trade name of the product or any changes in the label of the product will result in new registrations according to the guidelines described in the link above.
- Through the NRCP kept in the Directorate of Energy, Industrial and Chemical Products of GCSL, the Greek Poison Centre has electronic access to information required by the medical personnel in order to provide adequate care in cases of emergency.
- If your products fall under the Reg. 648/2004/EC, then according to art. 9, §3 and Annex VII, part 3 of the said regulation and art. 3, §3 of the Ministerial Decision 381/2005, any manufacturer (as defined in Reg. 648/2004/EC) responsible for placing the product on the market, who is established within EU, also has to provide the full list of ingredients (exact composition) of your product to the Greek Poison Centre using the following link http://0317.syzefxis.gov.gr/wp-content/uploads/2013/11/PoisonRegistrationForm.pdf , again regardless the quantity of the product.
- In order to conform with §1.4 of Annex I of Reg. 453/2010/EC, as amended and in force, you have to mention on the MSDS as Emergency Telephone Number the number of the Greek Poison Centre located at Aglaia Kyriakou Children’s Hospital, which operates 24h/day, 7 days/week and which you mention on your e-mail.
«Τηλέφωνο Έκτακτης Ανάγκης Κέντρο Δηλητηριάσεων Νοσ. Παίδων Αγλαΐα Κυριακού 0030 210 7793777»
- The MSDSs should be in Greek for products placed on the Greek market (art. 31, §5 of Reg. 1907/2006/EC – REACH).
- All the above are free-of-charge.
- The National Competent Authority for Plant Protection Products and Biocides is the Directorate of Plant Protection, General Directorate of Sustainable Plant Production, Ministry of Food and Rural Development, E-mails: email@example.com ; firstname.lastname@example.org
- The National Competent Authority for Biocides for human use is the National Drug Organisation, , E-mail: email@example.com
Hoping to have elucidated the situation for you
The Hellenic HelpDesk for REACH, CLP and BPR
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