As a horizontal piece of legislation, CLP has a wide-ranging impact, with any change likely to have a knock-on effect on various sectors, including but not limited to biocides, pesticides, detergents, cosmetics, toys, and medical devices. For example, CLP Self-classification of substances is being included in horizontal regulations to trigger requirements without an assessment of impacts (e.g. urban waste water treatment directive, taxonomy). Revising CLP means changing the foundation of one of the most comprehensive pieces of legislation in the world and it is important to consider sectorial implications.
Consumers and professional users buy paints, detergents, glues, inks etc., not chemicals. They purchase products made by DUCC members or articles containing products made by DUCC members. Since its creation in 2001 DUCC has acted with a united objective to contribute to the successful implementation of the REACH and CLP Regulations. DUCC raises the following points on the revised CLP text.