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CHIP Relabelling?
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#1 Posted : 09 January 2008 10:04:00(UTC)
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Posted By claire lewis We currently obtain various substances from our parent company in the States. We then sell these on to various customers within the EU. My question is to do we have to relabel the containers to comply with EU legislation (ie CHIP)? or can we just leave labels as they are? (We do not process these substances, we just sell them on). The substances we are selling have different classifications in the States than the EU. Thanks.
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#2 Posted : 09 January 2008 11:17:00(UTC)
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Posted By garyh I believe (as a lapsed DGSA!) that you as the IMPORTER are responsible for the CHIP labelling. Check with your DGSA (surely you should have access to the services of one?). Try the Chemical Hazard Communication Society who will be able to advise http://www.chcs.org.uk/index.htm
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#3 Posted : 09 January 2008 11:56:00(UTC)
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Posted By Simon Shaw In my opinion, you don't just have to relabel the containers, you also need to classify the substance and be able to justify your classification. In addition, you will need to produce and supply safety data sheets if the substances are for use at work. Are you sure that the classification given to a substance in the US will be the same classification over here?
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#4 Posted : 09 January 2008 12:07:00(UTC)
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Posted By Simon Shaw Sorry, just noticed that you already state that the classifications are different between the US and here. This makes it even more important that you classify the substances yourself.
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#5 Posted : 09 January 2008 12:45:00(UTC)
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Posted By Bob Youel you also have to consider consumer protection law e.g. 'fit for purpose' etc as a tablet could be mistaken for something else if it is not clearly labeled etc and medical professionals need accurate info in case of emergencies etc
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#6 Posted : 09 January 2008 13:43:00(UTC)
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Posted By claire lewis Thanks for your responses. We already do relabel the drums with the EU classification and provide MSDS's, etc etc - so we are doing the right thing. Just thought I'd check as big boss in states doesn't like us doing it because the EU classification makes one particular substance classified as Toxic (carcinogenic) whereas in states its not!!
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