It is now a legal requirement to submit information to 'Poison Centres' on hazardous mixtures placed on the market in the European Union. Different timeframes apply. Most ESMA printing ink members are producing inks for industrial use and can benefit from reduced requirements and transitional timescales. ESMA has produced this statement to clarify the position.
Industrial use mixtures: submission of information on hazardous mixtures in accordance with Annex VIII of the CLP Regulation
The submission of information on hazardous mixtures in accordance with Annex VIII of the CLP Regulation, so called Poison Centre Notification (PCN) is subject to the following deadlines:
- 1 January 2021 for hazardous mixtures supplied to consumers;
- 1 January 2021 for hazardous mixtures supplied to professional users;
- 1 January 2024 for hazardous mixtures supplied to industrial users.
PCN applies to all mixtures placed on the market that are classified for physical or health hazard. It does not apply to mixtures that are classified only for hazards to the environment, or the following exempt product categories:
- Radioactive mixtures;
- mixtures subject to customs supervision;
- mixtures used in scientific research and development;
- medicinal and veterinary products, cosmetic products, medical devices and food and feeding stuffs and;
- mixtures only classified as gases under pressure and explosives.
The printing inks that are manufactured and used by ESMA members are normally classed as inks for industrial use.
Industrial use is generally considered to apply when there is a high level of environmental health and safety (EHS) management practices among end-users, termed advanced EHS practices.
“Advanced practices are associated with training of workers, proper work instructions, supervision and regular cleaning and maintenance.”
Mixtures that are supplied only for industrial use may also benefit from a limited notification. Submission of a safety data sheet, along with a 24-hour emergency contact for rapid access to compositional information on the hazardous mixture is sufficient to satisfy the limited notification requirement.
Contact your ink supplier for further information and advice.
This document has been prepared by the Chair of ESMA’s Health, Safety & Environmental Protection Committee