CLP application to nanomaterials: a specific aspect.

This paper aims at describing some relevant aspects related to the classification, labelling and packaging of nanomaterials. Concerns have been raised about potential adverse effects to humans or the environment as result of impacts of nanomaterials. The new Regulation (EC) no. 1272/2008 on classification, labelling and packaging of substances and mixtures (CLP) does not contain any specific definition or provision related to nanomaterials nevertheless they are covered by the definition of substance set in the Regulation. It is recognized that different particle sizes or forms of the same substance can have different classification. Thus, if substances are placed on the market both at nanoscale and as bulk, a separate classification and labelling may be required if the available data on the intrinsic properties indicate a difference in hazard class between the two forms. CLP Regulation requires the manufacturer or importer to ensure that the information used to classify relates to the forms or physical states in which the substance is placed on the market and in which it can reasonably be expected to be used. Moreover, CLP demands testing relating to physical hazards to be performed if such information is missing or not adequate to conclude on classification. Further developments of the CLP guidance documents and implementation tools are needed in order to cover nanomaterials more specifically.