This includes, of course, changes in the regulatory status of products we provide, as we know such changes may affect the way products and materials are labelled, packed, handled, and transported.
All products containing >5% L-Lactic acid must be classified as Skin Corrosive Cat 1C, according to GHS calculation rules, unless testing results on your product prove otherwise; test results always take precedence over calculation rules. Be sure to take into consideration any other skin corrosive ingredients that may be present in your product. This >5% limit also applies to buffered lactic acid mixtures where lactates are added.
The classification change applies to the chemical L-Lactic acid (CAS 79-33-4), i.e. is in principle independent from the physical form it is available. However, Corbion possesses skin corrosion studies with several of our lactic acid powders. The results show that these powders are non-corrosive to skin and therefore do not have to be treated as dangerous good. Our SDS show the correct classification per product.
Although, strictly speaking, these substances are not included in the classification, labelling, and packaging (CLP) regulation Annex VI (translation of the GHS for EU), Corbion as the global market leader chooses to harmonize the classification and labelling of all lactic acid CAS#. The reason is simple: D-Lactic acid does not behave differently on skin than the L-isomer.
This change has no impact on lactic acid derivatives; under GHS, they retain their current classifications.
The new classification requires that lactic acid be stored as a corrosive material. Storage regulations are defined at the national level (for example, MIE-APQ in Spain, PGS15 in the Netherlands, GefstoffVO/TRGS 510 in Germany). For detailed guidelines, please refer to your country-specific legislation.
The new classification requires that lactic acid be stored as a corrosive material. Storage regulations are defined at the national level (for example MIE-APQ in Spain, PGS15 in the Netherlands, GefstoffVO/TRGS 510 in Germany). For detailed guidelines, please refer to your country-specific legislation.
The new classification as skin corrosive implies that lactic acid falls under the ADR regulation where applicable. Lactic acid was included in the generic UN number “UN 3265 for class 8 - Corrosive liquid, acidic, organic, n.o.s.” Corbion has applied the ADR requirements since 1 March 2022 , the date by which the new CLP classification (Annex VI) had to be applied.
As the new classification of L-Lactic acid applied beginning 1 March 2022, Corbion has updated the REACH dossier accordingly.
All GHS countries apply the same calculation rules for skin irritation/corrosion. Corbion is applying the EU change from Skin Irritant Cat 2 into Skin Corrosive Cat 1C also in all other countries.
Companies importing lactic acid must apply the EU-GHS (CLP) rules, i.e., use the new classification of L-Lactic acid.
Producers outside Europe must apply the GHS rules of the country where they put the lactic acid on the market.
Packaging for lactic acid must be UN compliant, Class 8 - PGIII.
This hazard phrase is a EU only requirement and does not fall under GHS. This statement is: “corrosive to the respiratory tract.”