European Commission Corrects Nitric Acid Concentration Boundary In Bulgarian CLP Text

The correction applies to Commission Delegated Regulation (EU) 2020/1182, commonly known as the 15th Adaptation to Technical Progress to the Classification, Labelling and Packaging Regulation. It does not create a new substance classification or reopen a proposal. It repairs the Bulgarian legal text governing an existing harmonised classification entry.

The separate nitric acid entry under index number 007-030-00-3 continues to cover concentrations at or below 70%. The corrected wording therefore removes an apparent overlap and confirms that a product containing exactly 70% nitric acid remains within the lower-concentration boundary, not the corrected greater-than-70% condition.

What Changes And What Remains Unchanged

Only the concentration condition shown for index number 007-004-00-1 in the Bulgarian text is corrected. The corrigendum does not alter nitric acid's identity, introduce a new transitional period or replace the wider Classification, Labelling and Packaging duties that already apply to suppliers.

Manufacturers and importers must continue to classify covered substances and mixtures, prepare compliant labels and packaging, and supply safety data information where required. Downstream formulators must still apply the concentration limits and mixture-classification rules relevant to their products. Employers' duties to assess corrosive and oxidising risks, control exposure and train workers also remain in place.

The practical effect depends on how a business encoded the two Annex VI entries in its regulatory data. A system that followed the erroneous text literally may have placed high-concentration products in the wrong record, created duplicate matches below 70%, or applied an incorrect reference at the exact 70% boundary.

Checks For Suppliers And Downstream Users

Suppliers should search product master data for nitric acid, index number 007-004-00-1 and mixtures close to 70%. They should then verify the selected Annex VI entry, concentration, classification rationale, label and safety data sheet. Updates should be controlled through normal change-management procedures rather than assuming that every nitric acid document must change.

Distributors and downstream users should ask suppliers to clarify any document that cites the high-concentration entry for a product at 70% or below. Workplace assessments should also be checked where regulatory classifications flow automatically into control bands or storage rules.

A one-character mathematical correction can have disproportionate consequences in automated compliance systems. Organisations should correct the underlying rule and rerun affected product records, not merely amend a single template, because the same concentration logic may feed labels, safety data sheets, transport reviews and site controls.