Have you already determined if an update of your “commodo” authorisation is mandatory due to the new “Omnibus” law?

Classified installations according to the Law of 10 June 1999, known as “commodo”, are subjected to a strict legislation. The “Omnibus” law of 3 March 2017 aiming at administrative simplification modified the law on classified installations with effect from 1 April 2017. It sets the transitional period to comply with the changes of the “commodo” nomenclature of 2012 at 31 December 2018 (Law of 2 August 2018).

Installations concerned by the changes of the nomenclature of 2012 are, among others, also installations storing and using chemical products. Here, the criteria to define the respective “commodo” class have changed substantially. If these changes result in a “commodo” class change for an existing authorisation, companies have to act by 1 July. They have to respect at the same time the requirements of the CLP Regulation (Regulation (EC) 1272/2008 on the classification, labelling and packaging of substances and mixtures).

The “Commodo/CLP Toolkit” allows companies to easily determine their “commodo” class and if there is a possible change of class.

It consists of three documents:

  • The Commodo/CLP Excel Tool: A simple and functional tool, in the form of an MS Excel file, to collect your data and define your “commodo” class.
  • The Commodo/CLP Guide: The guide presents the legal modifications, helps the user to fill in the tool and explains the consequences of the outcome
  • A case study based on the experience of the Luxembourgish company LCI Flowey Sarl that you can directly download here.

The methodology is based on the following steps:

  •  Compiling an inventory of the hazardous substances and mixtures present in the company
  • Based on the inventory, defining the CLP signal words and quantities for each substance and mixture to allow allocating them to the “commodo” nomenclature points n° 010128 or n° 010129
  • Determining the “commodo” class applicable
  • Evaluating if a change of class is mandatory and if an authorization (re-)application is needed
  • Identifying the specific administrative process to follow.

The Commodo/CLP Tool, its guide and the case study can be downloaded, free of charge by filling in the form provided below.

After submitting the form you will automatically receive an e-mail with the Commodo/CLP Excel Tool (Excel file), the related guide (pdf) and the case study. If you have not received the message within a few minutes please check the e-Mail address you provided.

This tool is made available by the Luxembourg Institute of Science and Technology free of charge under the conditions of the Creative Commons License (Attribution-NonCommerical-ShareAlike 4.0 International).

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