This section asks some basic questions about your company. Please answer this questionnairefrom the perspective of your legal entity if you undertake your own classification and labellingactivities. If classification and labelling activities are centralised across your corporate group,please respond for the group.

About you and your company

CLP Importers

Name

Company

Country

Email Address

Phone Number

1. Please complete the information below.

Please note that if your name and contact details are not provided, your reply may not be fully taken intoaccount as there will be no possibility of contacting you for further clarification or for managing potentialduplicate responses. Please also note that all responses from individual companies will be treated asconfidential and will not be linked to the specific respondents.

*

2. Please indicate the country(ies) where you place your products on the market.

Austria

Belgium

Bulgaria

Croatia

Cyprus

Czech Republic

Denmark

Estonia

Finland

France

Germany

Greece

Hungary

Iceland

Ireland

Italy

Latvia

Liechtenstein

Lithuania

Luxembourg

Malta

Netherlands

Norway

Poland

Portugal

Romania

Slovakia

Slovenia

Spain

Switzerland

Sweden

UK

3. Please indicate whether you are answering on behalf of your company (legal entity) or a group ofcompanies?

Single company Group of EU companies Global group of companies

4. Please indicate which of the following best describes the size of your company/your group ofcompanies? When answering this question please respond in line with the European Commissiondefinition of what is a SME.

- Micro-enterprise: (staff < 10, turnover < €2 million, balance sheet total < €2 million)- Small enterprise: (staff < 50, turnover < €10 million, balance sheet total < €10 million)- Medium enterprise: (staff < 250, turnover < €50 million, balance sheet total < €43 million)- Large enterprise: (staff > 250, turnover > €50 million, balance sheet total > €43 million)

See for further details:http://ec.europa.eu/DocsRoom/documents/10109/attachments/1/translations/en/renditions/native

Micro-enterprise

Small enterprise

Medium enterprise

Large enterprise

5. How many substances do you currently have in your portfolio?

<25

25 to50

50 to 100

100 to 250

250 to 500

>500

6. How many mixtures (formulations) do you currently have in your portfolio?

<50

50 to100

100 to 250

250 to 500

500 to 1500

>1500

7. What EU sectors do you mainly supply? Please tick all that apply

Inorganics

Synthetic Rubber

Paints and inks

Industrial gases

Man-made fibres

Auxiliaries for industry

Fertilisers

Speciality chemicals

Consumer chemicals

Polymers

Dyes and Pigments

Petrochemicals

Plastics

Crop protection

8. Do you also export to any of the following groups of countries? Please tick all that apply.

Turkey

Russian Federation and other non-EEA European countries

South & Central America

North America

Middle East

Northern Africa

Sub-Saharan Africa

Indian Sub-continent

China

Asia (excluding China and the Indian Sub-continent)

Australia and New Zealand

Other

9. Have all countries you export to implemented the UN GHS?

Yes No

<20% by value (€) <60% by value (€) >60% by value (€)

% turnover related to the EU import of substances

% turnover related to the EU import of mixtures

Do these percentages vary significantly on an annual basis?

10. On average, what percentage of your annual turnover (by value) is related to the import ofsubstances or mixtures into the EU?

Classification

Classification under the CLP Regulation

CLP Importers

Sales in the EU

Sales outside the EU

Total EU and non-EU

11. From 2016 onwards, out of the total number of Full Time Equivalent staff employed by yourcompany, how many FTEs will be involved in the classification and labelling needed to place yourproducts on the market?

Please provide the number of FTEs with CLP in the boxes below. To the degree possible, please tryand differentiate between the workload related to CLP versus that stemming from REACH.

Sales in the EU

Sales outside the EU

Total EU and non-EU

12. Do you believe that the number of Full Time Equivalent staff needed for classification in the future(2016 onwards) would be higher or lower if CLP (as implementation of the GHS) had not beenimplemented in the EU?

Please provide the number of FTEs without CLP in the boxes below and where possible explain whetherthe number of FTE would be higher or lower.

≤€300 €300-€500 €500-€750 €750-€1,000 €1,000-€3,000 ≥€3,000 Don’t know

Re-classification of mixtures(before CLP)

Re-classification of substances(before CLP)

Re-classification of mixtures (afterCLP)

Re-classification of substances(after CLP)

13. Previous studies estimated that the average cost of classification/re-classification under the CLPRegulation per mixture would be around €400. This estimate included the following actions:

- Gathering the available information (i.e. not including the costs of any testing) needed to undertakeclassification- Reviewing the available information to ensure it is adequate and reliable- Evaluating the available information against the classification criteria- Deciding on the appropriate classification for self-classification purposes, and- Paying any consultancy fees

Based on your experience, what is the average cost of classifying a substance and/or a mixture underCLP (and its implementation of the GHS compared to the cost before the introduction of the CLP (i.e. inline with the EC Dangerous Substances and Dangerous Preparations Directives)?

14. How often do you use or refer to ECHA’s Classification and Labelling Inventory in an average year?

Never

Rarely

Monthly

Weekly

Multiple times per week

Very important Not very important

Annual up-dates of IT software

Monitoring differences in EU uptake of GHS building blockscompared to other nations

New test and other information coming available from REACHor other such sources

On-going reviews of available classification data (e.g. data onECHA’s Classification and Labelling Inventory)

Changes in GHS agreed at the UN Level

Agreement of new harmonised classifications (CLH) under CLP

15. On an annual basis, how important do you expect the following to be to the costs incurred by yourcompany? Please tick the most relevant response

Relied on the use of the bridging principles?

Relied on expert judgement or weight of evidence approaches?

Already held mixture specific test data

Undertook new testing for classification purposes

16. With regards to the classification of mixtures under the CLP Regulation, please indicate thepercentage of substances and/or mixtures where each approach was taken:

Substances Mixtures

None

<10%

<30%

<60%

<90%

>90%

100% (all formulations)

Don’t know

17. What percentage of substances and mixtures (by number) in your portfolio of imports changedclassification as a result of CLP?

We removed some substances/mixtures from our products

We substituted some chemicals with less hazardous ones

We lowered concentrations of some substances/mixtures in ourproducts

We stopped importing some products into the EU

Other (please specify)

18. Has re-classification under CLP had a significant impact on the formulation of your products?

Please indicate the extent to which each of the following applied.

19. Manufacturers and importers have to notify ECHA of the self-classification of substances for entryinto the Classification and Labelling Inventory (CLI). Do you believe notifications to the CLI should alsobe made for mixtures?

Yes No

Yes No

Were you aware of this possibility?

Have you thought about takingadvantage of this possibility?

20. Manufacturers are able to request that a substance be given a harmonised classification under CLP,for example to ensure that all manufacturers and importers placing the substance on the market areadopting the same classification.

21. Do you have any comments you would like to make about classification under CLP?

Disseminating information

Classification under the CLP Regulation

CLP Importers

≤€500 €500-€1,000 €1,000-€2,500 €2,500-€5,000 ≥€5,000 Don’t know

Costs of updating SDS

22. Please estimate the average costs per substance or mixture of updating a safety data sheet (SDS)due to changes in substance or mixture classification.

Effectiveness in communicating information Costs of communicating information

Safety data sheets

Labels

Product websites

Bar codes / Q-R codes

Other (please specify)

Other (please specify)

23. Are the tools or systems, such as labels and safety data sheets, used to communicate hazard andrisk information to downstream users the most appropriate for doing so? Please rank the following interms of both their effectiveness and cost implications on a scale of 1-5 where 1 is best.

Labelling costs

CLP Importers

24. For what percentage of your portfolio have you had to modify labels due to Adaptations to TechnicalProgress (ATPs) under CLP?

<10%

<20%

<40%

<60%

>60%

None

Don’t know

Please explain your answer

25. Is the 18 month transition period allowed for responding to changes in labelling required as a resultof Adaptations to Technical Progress long enough?

Yes No

Packaging costs

CLP Importers

% of products whichchange in packagingrequirements due to

change in classification% of products now

requiring CRCs% of products now

requiring TWDs% of products now

requiring 'other' changes

No products

<5%

<20%

<40%

<60%

>60%

Don’t know

Further details

26. Did you have to change the packaging for any of your products as a result of CLP? If so, for whatpercentage of products? For what percentage of products did this change result in the need for childresistant closures (CRC), tactile warnings of danger (TWD) or something else?

Re-design and testing costs

Change in packaging material

Change in production lines

Disposal of obsolete packaging

Change in packaging design for safety

Other

27. If you had to change your packaging, what was the average cost per product line(€)?

28. What changes in classification led to the need for these other changes in packaging?

Please list the classification category(ies).

Linkages to other legislation

CLP Importers

Agree Disagree Don't know

The process is transparent and clear

There are no barriers to participation in the process

Decision making occurs in a timely manner

The process is accessible to SMEs as well as larger companies

The process is objective

The process is appropriate for agreeing harmonised hazardclassifications

29. Following the receipt of a Harmonised Classification proposal from a Member State, ECHA willundertake an accordance check and the proposal (dossier) will be published for public consultation. Consultation responses are then taken into account by the Risk Assessment Committee (RAC) whenforming their opinion on the proposal. This opinion is then sent to the Commission for decision making.

Please indicate whether you agree with the statements given below.

Yes No Don't know

Have you ever submitted a proposal to a Member State?

In your experience, have the proposals you have submitted tothese competent authorities always been forwarded to ECHA?

If not, please note the number of proposals you have submitted to a Member State competent authority and the number of thesewhich were not forwarded to ECHA

30. Article 37(6) of CLP legislation stipulates that manufacturers, importers and downstream users whohave new information which may lead to a change in the harmonised classification and/or labelling of asubstance in Part 3 of Annex VI are obliged to submit a proposal to the competent authority in one of theMember States in which the substance is placed on the market.

Please explain your answer

31. Have any of your substances or the substances used in your mixtures been given a classificationunder other legislation, e.g. under the Plant Protection Products Regulation or the Biocidal ProductRegulation? If yes, which legislation did this relate to and what action did you have to take?

Yes No

Other (please specify)

32. Have changes in classification under CLP led to changes in the costs to your company under anyother EU legislation?

Please tick the relevant legislation

Biocidal Products Regulation

Plant Protection Products Regulation

Carcinogens and Mutagens Directive

Toy Safety Directive

Cosmetics Directive

Seveso Directive

Prior Informed Consent Regulation

REACH Regulation

Waste legislation

Fertiliser legislation

Ecolabel legislation

Detergents Regulation

International transport legislation

Other (please list)

Yes No Don't know

To your company?

To your customers?

To transport / shipping companies?

33. Are the rules regarding labelling of outer packaging, inner packaging and over-packs clear underCLP and transport legislation?

Imports

CLP Importers

34. The CLP Regulation implements the UN GHS system of classification and labelling.

Please select those statements with which you agree?

Classification, labelling and packaging costs vary across the countries my company exports to because of differences in take-up of UN GHS building blocks, categories and sub-categories (please answer Q35)

Classification and labelling costs for exports have decreased due to implementation adoption of CLP and hence greaterharmonisation with the UN GHS (please answer Q36)

Classification and labelling costs for imports have decreased due to implementation adoption of CLP and hence greaterharmonisation with the UN GHS (please answer Q36)

Classification and labelling costs are lower for countries that have adopted the UN GHS than for those that have not adoptedthe UN GHS

There have been no savings in classification and labelling costs due to the more global adoption of the UN GHS system

35. What is the biggest reason for these differences in costs:

Differences in take-up of building blocks

Differences in take-up of categories and sub-categories

Differences in labelling requirements which remain due to differences in implementation

Differences in packaging requirements which remain due to differences in implementation

Rate from 1 to 5 (low to high)

Adoption of the UN GHS in the EU through implementation ofthe CLP Regulation

Adoption of the UN GHS in North America

Adoption of the UN GHS in China, Japan and other Asiancountries

Adoption of the UN GHS by Brazil and other South Americancountries

Adoption of the UN GHS in other countries (e.g. South Africa,Australia)

36. Please rate how significant the savings have been for your company due to the following on a scaleof 0 to 5 (where 1 is low and 5 is high).

It has reduced the classification and labelling costs of importingto the EU by X%

It has enabled us to increase our imports into the EU by X%

It has enabled us to sell mixtures in the EU at a lower price for X%of mixtures

It has enabled us to sell in more markets within the EU (i.e.number of EU countries) X% of mixtures

37. Has the adoption of the UN GHS in the EU through implementation of the CLP Regulation madeimporting to the EU easier for your company? If yes, please answer the following by filling in theappropriate percentage change figure:

Potential impact relating to sales / portfolio

Flammable liquids, Cat 4

Acute toxicity, cat 5

Skin corrosion/irritation, Cat 1A andCat 3

Serious eye damage/eye irritation,Cat 2A and Cat2B

Aspiration hazard, Cat 2

Acute hazards to aquaticenvironment, Cat 2 and Cat 3

Further details

38. Would the EU’s adoption of the following building blocks have had an impact on your sales orproduct portfolio? What impact would it have had with regards to health and safety and protecting theenvironment?

Future impacts

CLP Importers

39. Is there one particular aspect of CLP implementation that disproportionately accounts for its costs?

Strongly

agree Agree Neutral DisagreeStrongly

agree Don't know

CLP Regulation is consistent with wider EUpolicies in achieving the same general objectives(increased trade, human health, environmentalprotection)

EU-level intervention is necessary to achievethese benefits

CLP Regulation is consistent with internationalregulation on chemicals

EU-level implementation of CLP has madeinternational trade easier and more profitable

40. Please rate the extent to which you agree with the following statements relating to theimplementation of the CLP Regulation at an EU-wide level and its consequences for the internationaltrade of chemicals.

Largepositiveimpact

Lowpositiveimpact

Neutral/nochange

Lownegativeimpact

Largenegativeimpact Don't know

Harmonisation of classification and labelling

Harmonisation of packaging requirements

Access to markets for SMEs

The costs of substances placed on the EU market

The costs of mixtures placed on the EU market

41. Looking to the future, please indicate the extent of the positive/negative impacts for yourorganisation following the implementation of the GHS Regulation with regards to enhancing global tradeand competition.

Largepositiveimpact

Lowpositiveimpact

Neutral/nochange

Lownegativeimpact

Largenegativeimpact Don't know

Increased access to classification and labellingdata for substances

Increased number of substances with harmonisedclassifications

More consistent hazard classifications acrosssubstances

Hazard communication for workers

Hazard communication for consumers

Changes in packaging requirements

Preparedness for accidents

Links between CLP and other EU legislation

Links between CLP and national legislation

42. Looking to the future, please indicate the extent of the positive/negative impacts following theimplementation of the CLP Regulation with regards to health and safety.

Largepositiveimpact

Lowpositiveimpact

Neutral/nochange

Lownegativeimpact

Largenegativeimpact Don't know

Increased access to classification and labellingdata for substances

Increased number of substances with harmonisedclassifications

More consistent hazard classifications acrosssubstances

Hazard communication for workers

Hazard communication for consumers

Changes in packaging requirements

Preparedness for accidents

Links between CLP and other EU legislation

Links between CLP and national legislation

43. Looking to the future, please indicate the extent of the positive/negative impacts following theimplementation of the CLP Regulation with regards to protection of the environment.

Final remarks

CLP Importers

44. Do you have any final comments you wish to make about the implementation of the CLPRegulation?

45. Would you be willing to provide further information on specific issues?

Yes No