IMPORTANT: It is seller’s responsibility to comply with CLP. This material is for informational purposes only. It is not intended as legal advice. We encourage you to consult your legal counsel if you have questions about the laws and regulations concerning your product.
The ‘CLP’ Regulation (EC) No 1272/2008 on the classification, labelling and packaging of substances and mixtures, or simply CLP introduces the United Nations globally harmonized system (UN GHS) for classification and labelling of chemicals into Europe. As part of the EU laws regulating the sale of chemicals and dangerous substances, it is required that suppliers of chemicals transition from the Dangerous Preparations Directive (DPD) to the Classification, Labelling, and Packaging (CLP) regulation.
Changes will take place in the classification, labelling, and packaging of these products effective June 1, 2015. For example, let us say you sold a product that was a rust remover descaler containing phosphoric acid. Under DPD, the classification and labelling would look as follows:
Rust remover containing phosphoric acid under DPD
CLP applies to all substances and mixtures imported, manufactured or placed on the market within the EEA unless otherwise exempted. Examples of products regulated under CLP are paints, glues, spray paints and pesticides.
There are exemptions to the regulation for the following materials in their finished state only:
To determine if your product is regulated under CLP we recommend you take the following steps:
There was a phased transitional period which allowed time to change over from the existing rules. Many of these dates have passed, or are passing soon. Substances must be classified and labelled in accordance with CLP by December 1, 2010; or by December 2012 if already on the market. Mixtures must be classified and labelled in accordance with CLP by June 1, 2015; or by June 1, 2017, if already on the market.
Yes, as a seller it is your responsibility that your products are CLP compliant.
Products which bear any of the following CLP hazard statements are prohibited for Fulfilment by Amazon:
Risk Phrases prohibited in FBA
Explosive when dry
Explosive with or without contact with air
Reacts violently with water
In use may form flammable/explosive vapour-air mixture
May form explosive peroxides
Contact with water liberates toxic gas
Contact with acids liberates toxic gas
Contact with acids liberates very toxic gas
Risk of explosion if heated under confinement
Hazardous to the ozone layer
Explosive; mass explosion hazard
Explosive; severe projection hazard
Explosive; fire, blast or projection hazard
Heating may cause an explosion
Heating may cause a fire or explosion
Catches fire spontaneously if exposed to air
Self-heating; may catch fire
Self-heating in large quantities; may catch fire
In contact with water releases flammable gases which may ignite spontaneously
In contact with water releases flammable gas
Fatal if swallowed
Toxic if swallowed
May be fatal if swallowed and enters airways
Fatal in contact with skin
Toxic in contact with skin
Fatal if inhaled
Toxic if inhaled
May cause genetic defects
Suspected of causing genetic defects
May cause cancer
Suspected of causing cancer
May damage fertility or the unborn child
Suspected of damaging fertility or the unborn child
May cause harm to breast-fed children
Causes damage to organs
May cause damage to organs
Causes damage to organs through prolonged or repeated exposure
May cause damage to organs through prolonged or repeated exposure
Do not allow contact with air
Keep away from any possible contact with water, because of violent reaction and possible flash fire
Keep wetted with (insert manufacturer specification)
Handle under inert gas
Store in a corrosive resistant (insert manufacturer specification) container with a resistant inner liner
Maintain air gap between stacks/pallets
Yes, there are six DPD codes transitioning to CLP which are not accepted in Fulfilment by Amazon: DPD codes R18, R31, R32, R33, R64, and R65 will transition to CLP codes EUH018, EUH031, EUH032, H373, H362, and H304 which are prohibited in FBA (see affected risk phrases above). Please ensure you immediately discontinue sending these products into FBA.
It is seller’s responsibility to provide accurate and complete product information, including warning messages in the format we require. In order to add applicable warnings to your product listings, you should do the following:
Determine if the CLP Regulation (EC) No 1272/2008 on the classification, labelling and packaging of substances and mixtures, or simply CLP applies to your product. This may inter alia be verified by contacting the manufacturer or checking the product labelling.
If your products are regulated under CLP, verify that your products are eligible for sale on Amazon. If you want to use FBA, provide us with the completed ‘Product Compliance’ template that is available here.
You must not ship prohibited products into FBA. Amazon may at your cost and without compensation to you dispose of units regulated under CLP and prohibited for FBA.
We encourage you to visit the European Chemicals Agency (ECHA) for more information on CLP.
Product Compliance File
The Product Compliance template contains 5 tabs:
Please note that out of the 586 acceptable values, 41 values require additional information that may vary from one product to the other.
Let us take the safety phrase P261 that corresponds to ‘Avoid breathing …’: You will be required to enter an additional value like ‘gas’, in order to complete the phrase. If you miss entering the value, your upload will fail.
Once completed, upload your Product Compliance template in Seller Central.
In addition, when using FBA, you must submit for CLP regulated products the MSDS/SDS or an MSDS exemption sheet as applicable to Amazon. You can upload the MSDS or SDS using this link.
The upload takes 3 steps:
Please repeat this operation as many times as necessary (once per SDS).