Classification and labeling of alloy
Alloys are considered as special mixtures under the REACH and any implementation of GHS such as CLP Regulations and HzCom2012. Alloys as well as their components need to be classified and labelled in accordance with corresponding GHS implementation. The components of an alloy will have to be notified if they are hazardous and contained in an alloy above specified concentration limits, in accordance with same corresponding regulations.
Referring to the criteria of CLP regulation, in relation to classification for the aquatic hazard class, Annex IV, section 5.5, ’Classification of mixtures of metal compounds’, Guidance on the Application of the CLP Criteria notes that metal alloys, or alloy manufacturing products, are not simple mixtures of metals or metal components, since the alloy clearly has distinctive properties compared to a classical mixture of its component metals.
Regarding labelling, point 1.3.4 of Annex I to CLP provides that metals in the massive form, as well as alloys, do not require a label if they do not present a hazard to human health by inhalation, ingestion or contact with skin or to the aquatic environment in the form in which they are placed on the market, although classified as hazardous in accordance with the classification criteria of CLP and/or HazCom 2012. However, the supplier shall provide the information on the classification of an alloy to downstream users or distributors by means of the Safety Data Sheet.
According to point 2.7 of Annex II to CLP, special labelling rules apply to alloys containing cadmium and which are intended to be used for brazing or soldering. They shall bear the following statement: “Warning! Contains cadmium. Dangerous fumes are formed during use. See information supplied by the manufacturer. Comply with the safety instructions.” (EUH207).