A customer of us pointed to the following: in some language versions of the amending regulations to the CLP Regulation (“ATPs”), corrections of the wording of some H- and P-phrases have been made (the regulation deals for example with the field of application of the respective phrase). Corresponding changes in the multilingual tabular compilations of wordings for the various EU languages were omitted, however (since these tables themselves were not necessarily the subject of the respective ATP). Until a corresponding adjustment is made in a future ATP, the problem arises that there may exist two different wordings for the same H- or P-phrase.

Example: H222 “Extremely flammable aerosol”. In the current Italian consolidated version of the CLP regulation a changed/corrected wording is used in the table 2.3.1 “Aerosol estremamente infiammabile”, yet “Aerosol altamente infiammabile” stands in the multilingual compilation for the H222. Some buyers of our customer claimed that the “corrected text version according to Reg. 487/2013 (IT version)” should be used, based on a recommendation of the European aerosol Association FEA (Fédération européenne of the aerosol). However, the Italian CLP helpdesk told that generally only the wordings explicitly published in the compilation table should be applied.

The facts described here affect many other H- and P-phrases, not only in Italian language. We follow the opinion of the Italian CLP helpdesk and will only make changes if they are expressly adopted resp. published, such as the correction in the EU Official Journal of 21 December 2016 or the Regulation 2016/918 (8 ATP).