REACH & CLP

In brief

When it comes to health and safety and communicating with downstream users, the most relevant legislative texts are as follows:

  • REACH (Registration, Evaluation, Authorisation and Restrictions of Chemical substances), the role of which is to improve the protection of human health and the environment from the risks that can be posed by chemicals.  Under REACH, every substance manufactured or imported in the EU above 1 tonne must be registered by the entity that imports or manufactures it, unless it is exempt from registration. Furthermore, there is an obligation to communicate upstream (towards suppliers) and downstream (to customers) on substances by means of Safety Data Sheets (SDS) and chemical safety reports as the case may be. As defined by REACH, SDS are the key tool for hazard and risk management communication in the supply chain.
  • Classification, Labelling & Packaging (CLP) Regulation, which harmonises requirements concerning the classification, labelling and packaging of chemical substances and mixtures in line with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) approved by the United Nations.

Our view

The cement industry fully complies with the obligations laid out in the REACH and the Classification, Labelling and Packaging (CLP) legislations whose aim is to protect human health and the environment.

  • Harmonised information relating to emergency health response – Annex VIII to CLP:
  • According to Article 45 of the CLP Regulation, companies placing hazardous mixtures on the market are obliged to provide information about certain hazardous mixtures to the relevant national bodies. The national bodies make this information available to poison centres so that they can give advice to the citizens or medical personnel in the event of an emergency. Annex VIII to the CLP Regulation, adopted in March 2017, defines the harmonised requirements for poison centre notifications (PCN) applicable as of 1 January 2021. In addition, there is a grandfathering period until 1st January 2025 for importers and downstream users who have submitted information related to hazardous mixtures to a body appointed before the date of applicability.
  • CEMBUREAU has advocated on workability issues for the cement sector and worked out on the ‘standard formulas’ approach for cement. The final Commission proposal and 2nd amendment of the legal text foreseen in August 2020, is including standard formula concept.

Clinker is a substance and is thus exempt from REACH registration. Nevertheless, it must be classified and labelled and a Safety Data Sheet (SDS) must be provided, if it is placed on the market, and this C&L has been notified to the European Chemicals Agency.   Cement is a preparation and is therefore also not subject to REACH registration, although it must also be classified and labelled. Nevertheless, because it is a preparation, no C&L notification to ECHA is necessary. An SDS, possibly with an exposure scenario, must be provided.  In terms of CLP, please refer to image for classification used by all CEMBUREAU members, for Portland cement clinker and common cements. 

Furthermore, CEMBUREAU has prepared safety data sheet templates for its Members (covering both “Portland cement clinker” and “Common cements”) which take into account the REACH requirements.

Scientific studies have also shown that cement preparations containing chromium VI may cause allergic reactions in certain circumstances, if there is direct and prolonged contact with the human skin. All uses of cement bear the risk of direct and prolonged contact with the human skin, with the exception of controlled closed and totally automated processes (Directive 2003/53/EC).

Unless cements or cement mixtures are already classified and labelled as a sensitiser with the hazard statement “H317 May cause an allergic skin reaction”, the label on the packaging of cements and cement mixtures that contain, when they are hydrated, more than 0,0002 % soluble chromium (VI) of the total dry weight of the cement shall bear the statement: EUH203 — ‘Contains chromium (VI). May produce an allergic reaction’.

If reducing agents are used, then the packaging of cement or cement-containing mixtures shall include information on the packing date, the storage conditions and the storage period appropriate to maintaining the activity of the reducing agent and to keeping the content of soluble chromium VI below 0.0002 % of the total dry weight of the cement ready for use.

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European Chemicals Agency (ECHA)
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ECHA
Poison Centres Portal
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ECHA
EUCLEF: EU Chemicals Legislation Finder
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ECHA
Guidance on REACH
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Guidance
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Legislation
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ECHA
Consultations
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EUR-Lex
REACH Annex II – Requirement for the compilation of SDS
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