- The ‘EuPCS’ guidance was released by the European Chemicals Agency (ECHA) in June 2018 in order to provide support to describe ‘the intended use of a mixture’.
- This is for the purpose of Article 45 and Annex VIII of CLP (Regulation (EC) No 1272/2008). i.e. the submission of harmonised information relating to emergency health responses or more commonly referred to as ‘Poison Centre’ notifications.
- The submitter must assign a product category which best defines the intended use of that mixture which will be placed on the market.
- The scope of the guidance covers mixtures classified as hazardous under CLP but there are some exemptions in accordance with CLP Article 1(5) and Annex VIII, and the guidance may also be used for voluntary submissions for non-hazardous mixtures.
- There are almost 250 product categories, described in a 5-level hierarchical tree structure1:
1 The European Chemicals Agency (ECHA), The European product categorisation system: A practical guide, June 2018
* Parent categories branch down to the child level, a selection of a category can only be made at the lowest level in the hierarchy and if it can no longer be subcategorised.
* Category codes are alphanumerical.
* The first level is either ‘P – Products’ for end use or ‘F – Mixtures for further formulation’.
* The second level differentiates between chemical products, biocidal products and plant protection products.
* Selecting multiple categories for a single product is not possible and categorisation shall be made according to a single main intended use.
- For example, if a product is both ‘P – Products’ and ‘F – Mixtures for further formulation’, the main intended use should reflect the ‘end use’ in order to provide more information for an emergency health response.
- Further, BPR and PPPR products should be selected as the main intended use if such products also have a dual function, such as a detergent.
* Sometimes, no suitable category exists, and so in these exceptional cases the categories ‘Other…’ or ‘Chemical products – uncategorised’ should be used, but there is no possibility for the submitter to indicate their own specific category.
* Standard (single mixtures, can be multiple products) or group (multiple mixtures) submissions can be made, but all products in a group submission must have the same CLP classification for physical and health hazards and belong to the same category.
* Section 5 of the guidance has describes in detail all the subcategories belonging to the third level:
Figure 2. The European Chemicals Agency (ECHA), The European product categorisation system: A practical guide, June 2018
- It is highly recommended to read the full EuPCS description to select the correct category for your product.
- The tables within section 5 will lead to selection of the fourth and fifth level of the products codes, for example, the biocidal product types as described in Annex V of the BPR (Biocidal Products Regulation (EU) No 528/2012) are used as the fourth and fifth level.
- Annex I to the guidance also suggests corresponding EuPCS categories, where REACH use descriptors are available.
- The end result will be the EuPCS ‘code’ and a ‘label’ (a title) and sometimes a further ‘description’ is available. For example, the EuPCS code ‘PP-BIO-5’ is accompanied by the label ‘biocidal products for drinking water’ and the description is the same as that for product-type 5 (PT5) under the BPR “Biocidal products used for the disinfection of drinking water for both humans and animals.”
- The EuPCS needs to reflect legislative change, industry needs and the requirements of Member States’ poison centres and appointed bodies, therefore a process is currently being established to allow for this purpose but it must be a stable system and as such a compelling justification is needed for changing the EuPCS.
For further advice on this topic or any other chemical regulatory matter, please do contact the author, Philippa O’Donovan at Philippa.firstname.lastname@example.org or also email@example.com.