The CLH dossier prepared by a Member State, or manufacturer, importer or downstream user is submitted to the European Chemicals Agency (ECHA). ECHA checks that the dossier is in accordance with the legal requirements of the CLP Regulation Opportunity to advocate (processes ended in November 2022)

Step 1. Dossier Submission

A 60 day consultation period takes place in which interested parties are invited to comment on the CLH dossier Opportunity to advocate (processes ended in January 2023)

Step 2. Consultation

The CLH dossier, consultation comments and responses are sent to RAC. RAC has 18 months to adopt an opinion based on the evidence (Article 37(4) CLP Regulation) Opportunity to advocate (accredited stakeholders such as IFRA and EFEO can attend RAC meetings) (Process ended in November 2023)

Step 3. RAC Opinion

The Commission, assisted by CARACAL, prepares a delegated act for the classification and labelling of substances concerned “without undue delay,” with consultation of stakeholders (Articles 37(4) and 53a CLP Regulation). Opportunity to advocate (observers /experts may apply for observer status following a call for applications; observers may submit written comments to CARACAL) (in principle, only entities granted observer status can comment on meeting minutes)

Step 4. Legislative Process

The Commission adopts a delegated act and notifies the Council and the European Parliament, who have a period of two months to object (extendable by two months). Opportunity to advocate via Parliament / Council (difficult to lobby the Parliament / Council to object at this stage)

Step 5. Legislation Enters Force

At the 51st meeting of CARACAL (20-21 March 2024) and the 52nd meeting of CARACAL (1-2 July 2024), accredited stakeholders and observers including Stockton Europe Ltd, COSMED, EFEO, EFEAT, and Pure Australian Tea Tree Oil attended and made submissions