What to do if a mixture containing polymers is classified as hazardous but does not require labeling on the label?

This is a question that requires attention, especially in light of the requirements of the CLP Regulation and PCN notification.

In such cases, we rely on exception 1.3.4.:

1.3.4. Metals in massive form, alloys, mixtures containing polymers, mixtures containing elastomers

1.3.4.1.
Metals in massive form, alloys, mixtures containing polymers and mixtures containing elastomers do not require a label according to this Annex, if they do not present a hazard to human health by inhalation, ingestion or contact with skin or to the aquatic environ ment in the form in which they are placed on the market, although classified as hazardous in accordance with the criteria of this Annex.

1.3.4.2.
Instead, the supplier shall provide the information to downstream users or distributors by means of the SDS. 

Regarding the UFI code and PCN notification, the situation is somewhat different. Even though the mixture is not labeled as hazardous on the label, it still falls under hazardous chemicals and as such requires a safety data sheet and PCN notification in accordance with the relevant legislation.

Annex VIII of the CLP Regulation stipulates that the UFI code must be indicated on the safety data sheet or on label elements. This means that the UFI code is still required, but it can be listed on the safety data sheet or included in label elements, as the mixture remains classified as a hazardous chemical.

If you find yourself in a situation from which you cannot escape, for research purposes or if you fall under any exceptions but do not have the time, you can send me an email at spela.hudobivnik@bens-consulting.eu.

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