CLP

Current activity

The Lead REACH Consortium is actively involved in key technical work and advocacy related to the CLP Regulation, and REACH Registration dossier reviews to reflect appropriate classification at EU level.

The Consortium periodically reviews the classification of its substances in line with the latest scientific data and knowledge. For many of its substances, the Consortium has proposed self-classification that goes beyond the EU harmonised classification as set out in Annex VI to the CLP Regulation.

In consideration of the harmonised health classification for lead metal in the 9th ATP to CLP (Regulation (EU) 2016/1179; applicable since 1 March 2018), the Consortium updated its self-classification for all registered grades in June 2016. The Consortium also published an FAQ document (updated January 2019), written to address common questions about the harmonised classification introduced by the 9th ATP to CLP.

In light of a long-anticipated proposal from Denmark for harmonised environmental classification (ENV CLH) for Pb metal, the Consortium responded to the public consultation on the proposal, submitted new technical argumentation, and attended key meetings of the ECHA Committee for Risk Assessment (RAC) in 2018. In 2020, the registration dossier and CSR were updated to reflect the M-factors for Pb metal powder adopted under the 15th ATP to CLP (Commission Delegated Regulation (EU) 2020/1182; applies from 1 March 2022). The Consortium successfully requested an Art. 77(3) review in respect of the proposed harmonised classification of Pb metal in massive form; regrettably, despite sound scientific arguments and intensive advocacy, ENV CLH for Pb metal in massive form was introduced by Commission Delegated Regulation (EU) 2024/197 which takes effect from September 2025. The Consortium therefore plans to update the Pb metal REACH Registration dossier by Q3 2025 to adopt the harmonised classification.

Consequent to the publication of the ENV CLH for Pb metal massive and in response to stakeholder enquiries, the Secretariat has published guidance on classification for Transport.

The Consortium is an active member of the Eurometaux iUVCB Platform and is engaged in a comprehensive review of the substance identity profiles (SIPs), hazard assessment, classification, and reporting in IUCLID of the Consortium’s UVCBs. The Consortium uses ‘MeClas’, the metals classification tool, to classify its iUVCB substances. MeClas uses a tiered approach to classification of complex metal substances; a UVCB’s classification may be further refined by a registrant through the use of legal entity specific information, for example transformation/dissolution test data on their given substance.

Information on the latest classifications is available in the substance grade data sheets on the following pages: lead metal, lead compounds, UVCBs.

What is CLP?

CLP – the Classification, Labelling and Packaging Regulation ((EC) No 1272/2008) – is the EU’s implementation of the United Nations’ Globally Harmonised System (GHS). It has replaced the Dangerous Substances and Dangerous Preparations Directives, setting out the requirements for manufacturers, importers and downstream users to classify, label and package their hazardous chemicals appropriately before placing them on the market.

Find out more about the CLP Regulation.