DetNet is the Detergent Industry Network for CLP Classification. Developed and piloted by A.I.S.E. and its network of National Associations, in dialogue with stakeholders, this collective approach aims to help companies establish the appropriate skin and eye irritancy classification for their detergent products in compliance with the CLP Regulation (EC) No 1272/2008 due to come into effect June 2015 for mixtures.

 

The challenge

CLP is an important tool to assess and, as a result, alert consumers of product hazards. In order to ensure safe use of products, it is important that consumer can:

• Recognise the hazard
• Distinguish between products of different hazards
• Understand a relevant and adequate label.

 

Up to now, under CLP, a company has had two options available to classify and label its products (if the company does not have data on the mixtures themselves):

1. Accept the classification by calculation

This option would lead to many more daily use products being classified and those already classified today being more severely classified and labelled. The default classification would result in:

• The label not reflecting actual effects on man based on human experience
• Devaluing warning labels; no ability to differentiate really hazardous products if all products bear the same pictograms
• Leading to unsafe handling of the really hazardous products
• Confusing poison centres and consumers.

 

2. Generate in vitro data

Before applying this option, a company should take into account costs, complexity and lead time before obtaining a result, which will then determine the label.

 

Based on new CLP features, a new solution has been developed and piloted at sector level: DetNet.

A new solution: DetNet

DetNet, the Detergent Industry Network for CLP Classification, builds on the concept of an industry classification network introduced in Annex 1, 1.1.0 of the CLP Regulation (EC) No 1272/2008,

“...suppliers in an industry sector may cooperate through formation of a network (internal link to E1.4.) or by other means to share data and expertise when classifying substances and mixtures in accordance with Title II of this Regulation.”

Building on this provision, A.I.S.E. collectively explored options available under CLP to classify detergent mixtures with the view to secure the safe use of products for consumers, namely:

• Share data and expertise under the umbrella of an ‘Industry Classification Network’ and apply CLP bridging principles and expert judgement, so that not every mixture needs to be individually tested
• Generate in vitro test data for classification of detergent mixtures to populate the database.

 

The overall aim of DetNet is to provide means whereby all manufacturers/suppliers of detergents and cleaning products can have access to shared test data and expert judgment to allow for a science-based process for classification of products with respect to skin/eye effects, which is in line with CLP principles.

DetNet builds on the ‘bridging principles’ from the CLP Regulation by allowing a company with a given untested mixture to classify it by comparing it with similar tested mixtures, i.e. Reference Formulations from the database.

Reference Formulation compositions are made available to experts from companies using a fixed format that provides sufficient detail to enable comparison of mixtures and application of Bridging Principles, but still protects confidential business information of the data owner (e.g. no trade name of ingredient, use ‘perfume’ generically, etc.)

In addition, A.I.S.E. has prepared explanatory notes on the classification of detergents under CLP for skin/eye corrosion/irritation endpoints. This document includes inter alia a classification process flowchart (see here), worked examples to illustrate application of the various CLP bridging principles (see here) and examples of completed Classification Record forms (see here).

 

DetNet is open to all companies placing detergent or cleaning products on the market and responsible for classification and labelling for skin and eye effects under CLP in the EU plus other European countries with national CLP implementation:

• whether multinationals or small and medium-sized enterprises;
• whether members or non-members of A.I.S.E. or its National Associations;
• whether manufacturer, retailer or importer (agent).

 

Products in scope

The priority products for which DetNet is available are laundry detergents (liquids, powders), hand dish wash detergents and all-purpose cleaners (non-extreme pH products), for both consumer and professional use. DetNet reference formulations could also be used for other product types with similar chemistry (i.e. those based on surfactants for example car wash products). Other products with similar chemistry refers to product composition: for example, if a detergent for a different intended use has a similar composition to an all-purpose cleaner, DetNet can be of use. In other words, it is the composition of the mixture that matters, not the intended use or the product category.

Endpoints

Only skin and eye endpoints will be covered. Other endpoints, other hazards of relevance under CLP, will have to be assessed separately, for each mixture.

 

Disclaimer:

Whilst DetNet is a service proposed by the EU Detergent Industry (A.I.S.E.) for CLP Classification, A.I.S.E. reminds that each company placing products on the market is responsible for the final classification.

The unique features of DetNet include:

 

Web-based IT system

•  IT-system to search the database of Reference Formulations
• Security (individual access code), confidentiality of composition information

 

Data sharing for all users, expertise

• Ca. 200 formulations, including recent market representative products
• Recent in vitro data 
• Toxicological data quality and robustness assessed ('Klimish scoring')
• Toxicological study Summaries available to users
• Scientific Advisory Panel comprising experts from academia, who are consulted on science and expertise related matters

 

Standardised process and records

• Classification Record using a standard format
• Classification logging number as proof that an expert has used DetNet to derive classification
• Classification explanatory notes
• Composition details on reference formulations to enable a refined comparison of formulation compositions

 

Training and support

• Training of classification experts
•  HelpDesk support in the future
•  Frequently Asked Questions

 

Benefits for consumers

• Avoid confusion of consumers
• Reflect actual effects on man based on human experience
• Avoid devaluing warning labels
• Avoid unsafe handling of the really hazardous products

 

Benefits for companies

• Restrict negative impact on brand and claims
• Avoid limited retail shelf positioning
• Avoid additional transport, storage and labelling constraints