Relabelling obligations under the CLP Regulation (Regulation (EC) No. 1272/2008) in relation to the following biocidal products

The 13th Adaptation to Technical Progress (ATP) to the CLP Regulation (Commission Regulation (EU) No. 2018/1480) contains a number of new/revised harmonised classifications that require substances to be re-classified and labelled by 1st May 2020, including preservatives ‘MIT’ and ‘CMIT/MIT’.

If you use any of the following preservatives or active substances in your product, you should contact your supplier for updated AS SDS and ensure that your product SDS and label is updated before the legal deadline of 1^st May 2020. The legal obligation in the 13th ATP is to have MIT and CMIT/MIT and all products containing these preservatives to be classified and labelled in accordance with new/revised harmonised classifications by the due date of applicability in the ATP (i.e. 1st May 2020). This means that suppliers have 18 months to sell stocks of existing products already placed on the market or in the supply chain. However, Article 30 of the CLP Regulation is also clear that following any changes to the classification and labelling where the revised classification is more severe or where new supplemental label elements are required, suppliers are required to update information on the label without undue delay, i.e. as soon as reasonably practicable.