A Note About CLP Classification

In the European Union, ECHA (European Chemical Agency) is responsible for managing the registration of chemicals and mixtures. There are two parts to this, REACH and CLP.

CLP (Classification, Labelling and Packaging) regulations are part of a globally harmonised system. Producers, importers and other parties are required to register their chemicals and mixtures on the ECHA website, giving what they consider to be accurate assessment of the safety classification.

In theory, this should result in a chemical being classified the same by all parties concerned. In practice, this is not always the case.

An example of this is citric acid, which is found in oranges, lemons and limes. As of January 2015, there are 29 different classifications for it. About 300 have labelled it as STOT SE 3 (Specific Target Organ Toxicity Single Exposure level 3) and well over 2000 notifiers have it as eye irritant level 2. Bear that in mind next time you eat an orange! In fact, citric acid is officially "Not classified", i.e., harmless, and of the approximately 3000 notifiers, only 258 gave it this classification.

Unfortunately, this is also the situation with many perfluorocarbons.

Perfluorodecalin (known as perflunafene in the ECHA database) has three classifications, with 24 out of the 28 notifiers classifying it as flammable. It is definitely not flammable, and we have plenty of data that shows perfluorocarbons as a class are not flammable. However, there is no way we can even find out who the other notifiers are to ask them to revise their classification (there is a message board facility on the ECHA website, accessible only to notifiers of a particular chemical and we have left a message on there, but the chances are no other notifier will ever have a cause to look at the classifications and so will never know it is even there).

Why do so many notifiers consider it to be flammable? It is quite possible they all used the same consultant. It maybe they all used the same source or perhaps used a variety of sources, and one said it was flammable so they thought it was better to be on the safe side and label it as flammable just in case. It seems likely that all the other notifiers are traders selling large catalogues of chemicals in small amounts (we are the only EU manufacturer of many of our perfluorocarbons), and getting notifications done quickly and cheaply would be a priority over getting them done accurately.

The whole point of CLP is to have a harmonised system, and it is our hope that eventually these issues will be resolved, however that will certainly take many years.

F2 Chemicals is working towards registering several perfluorocarbons for REACH and this should help the situation (so far octafluoropropane and perfluoro-2-methylpentane have been successfully registered, with perfluorodecalin well on the way). As the primary producer of perfluorocarbons in the EU, we feel we have considerably more knowledge on these unique chemicals.