Question:

1. “Does the expiry date should appear on the labelling?”
2. “Is there any specific regulation of VOC’s compounds? Or any other that could affect to us?”
3. “Do we have to notify all the products? Or only the dangerous ones?”
4. “It is clear that the Emergency Telephone number has to appear on the 1.4 point of the MSDS. Should we add the same telephone number to the following P sentence? Or is it OK? “P301+P312 ΣΕ ΠΕΡΙΠΤΩΣΗ ΚΑΤΑΠΟΣΗΣ: Καλέστε το ΚΕΝΤΡΟ ΔΗΛΗΤΗΡΙΑΣΕΩΝ/γιατρό/…/εάν αισθανθείτε αδιαθεσία.”

Answer:

1. The elements that should appear on the label according to the Regulation 1272/2008/EK (CLP) are described in art 17 of CLP. The expiry date is not part of a CLP label. Nevertheless, there are other EU Regulations or national legislations that require an expiry date (eg Regulation 528/2012/EC). It is the responsibility of the supplier to produce a legislation-compliant label.
2. VOCs are covered by the Directive 2004/42/EC as amended and in force introduced in the National Legislation by the Ministerial Decision KYA 437/2005 (ΦΕΚ 1641/B/8-10-2006). For other relevant legislation, see points 4, 6, 7 of our response Ref No 30/004/000/1828
3. All mixtures placed on the Greek market classified as hazardous on the basis of their health or physical effects regardless the quantity of the product and its final use should be registered to NCRP.
4. The wording of H and P statements should be exactly as stated in the CLP Regulation. For detergents the emergency telephone number must appear on the label according to the National Joint Ministerial Decision KYA 129/2016 (ΦEK 1138/Β/31-3/2017).

 

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