Can we use GHS in Europe on our SDSs and labels right away?

Can we use GHS in Europe on our SDSs and labels right away? If not, when can we prepare a GHS MSDS or SDS for use in Europe?

The short answer is 'yes', the EU implementation of GHS, known as CLP (Classification, Labelling and Packaging of chemical substances and mixtures) allows for early adoption of GHS for both SDSs and labels, though the rules differ between pure substances and mixtures.

Mixtures - The new classification system is not required for mixtures until June 1, 2015. Companies are free to adopt the new CLP rules on their SDSs and labels for mixtures any time before that date.

Substances - Between December 1, 2010 and June 1, 2015 companies are required to use both the existing classification system and the CLP system on their labels and SDSs - that is, substances will be 'double classified'. After June 1, 2015 only the CLP system is required. Companies are free to adopt the CLP system prior to December 1, 2010, so long as they follow the 'double classification' provisions required between December 1, 2010 and June 1, 2015.

Note that, unlike REACH, there is no one tonne exemption under CLP.