Upcoming regulatory changes

From 1st of May 2020 the level for skin sensitizing classification of the commonly used preservative methylisothiazolinone (MIT) reduces from 1000ppm to 15 ppm regarding skin sensitization (CLP 1272/2008 Appendix VI). As lower levels of MIT are not effective, HAVO and also most of its raw material suppliers, are changing its preservative system in all products involved, to prevent HAVO products being classified as H317 (May cause an allergic skin reaction) preceded by an exclamation mark.

HAVO stands for quality and safety of its products for creative children and adults and therefore will change the recipes of the products involved and implements the consequence to labelling. None of our current products will therefore become classified as hazardous according to CLP.

Use of preservation is needed to prevent aqueous paints, glue and modelling material from being affected by micro-organisms like bacteria, yeast and fungi. For the last years EU legislation reduces the use of the commonly used biocides more and more, which challenges industry with a big challenge. HAVO is continuously following developments in industry and has chosen alternative solutions that fulfil REACH, BPR and Toy Safety Legislation. Some possibility of skin sensitization however remains (EUH208).

Another change in CLP (1272/2008 Annex VIII) will be that all manufacturers will have to register its hazardous products from 1st of January 2021 in a central poison centre register (ECHA Submission Portal) using an Unique Formulation Identifier (UFI), which also has to be placed on the label. As HAVO does not manufacture hazardous products, registration is not obligated and HAVO therefore will not have UFIs for its products. Also private labels do not have to register their products obtained from HAVO. Of course we still keep serving national poison centres with information regarding our products when asked for.

Regulatory services to you
Developments in legislation regarding responsibilities of economic operators become more and more strict in Europe. HAVO strictly complies to all EU regulation and maintains an accurate compliance system for you. We always provides you with the necessary up to date documents to prove compliance based on REACH, EU Framework and Toy Safety Directive.

Safety Data Sheets (SDS) are intended for professional users only (REACH 1907/2006) and are only obliged for hazardous products, which HAVO does not manufacture. Nevertheless, to stay serving you accurately and compliant to our role as manufacturer you can obtain actual Safety Data Sheets from all our Creall products in English. A SDS is related to the mixture we formulate and therefore we create an SDS based on the family of end products related to a colour-series of products independent of packaging or sets. Therefore no article numbers will be placed on our SDS.As HAVO stays responsible as a manufacturer in the economic chain, the SDS will always mention HAVO as a manufacturer unless laid down in a private label contract. From now you can download the Creall Safety Data Sheets yourself on our FTP server: ftp://file.havo.com

Next to this you can request up-to-date Declarations of Conformity (DoC) / CE-declarations for all our Creall toy products in English. Creall DoCs can be obtained from your contact person from HAVO.
Private labels can request both type of documents in one language of choice through your contact person from HAVO or directly at ra@havo.com.