For Until 01 June 2015
Mixtures have to be classified, labelled and packaged in accordance with the DPD until 01 June 2015. In addition, mixtures may be classified, labelled and packaged according to CLP before 01 June 2015 (in this case, DPD labelling and packaging provisions do not apply).
If CLP is applied to a mixture before 01 June 2015, the Safety Data Sheet (Annex II REACH) must contain both the DPD and CLP classifications of the mixture.
Mixtures classified, labelled and packaged according to the DPD and already placed on the market before 01 June 2015, do not require re-labelling and re-packaging according to CLP until 01 June 2017.
After 01 June 2015
DSD and DPD are repealed; only CLP remains in force. Where a mixture has been classified according to the DPD before 01 June 2015, suppliers may amend the classification of the mixture using the translation table in Annex VII (Art. 61.5 – similar provisions apply to substances classified before 01 December 2010). It should be noted however that (i) direct translation is not possible for certain endpoints and (ii) Annex VII indicates that an evaluation and classification must be carried out in accordance with Articles 9 – 13 when data for the mixture are available.
A supplier cannot decide to apply CLP for certain hazard classes only during the transitional period. If a supplier decides to apply CLP for mixtures before 01 June 2015 then they must implement CLP provisions in full.