Classification and labelling obligations were first imposed by EEC Directive 67/548 of 27 June 1967 (Dangerous Substances Directive) and its subsequent 31 adaptations to technical progress, in particular Directive 97/69/EC of 5 December 1997 EC relating to classification of man-made vitreous (silicate) fibres.
EC Regulation No 1272/2008 of the European Parliament and the Council of 16 December 2008 (CLP) on classification, labelling and packaging of substances and mixtures, as amended from time to time, is replacing step by step the Dangerous Substances Directive and the Dangerous Preparation Directive 1999/45 EC. It entered into force on 20 January 2009; classification and labelling obligations came into effect on 1st December 2010 and the latter directives will finally be repealed on 1st June 2015.
The harmonized classification and labelling system of the Dangerous Substances Directive has been translated into a new system. Although the classification itself is not altered, labels, pictogrammes, signal words, hazard communication and precautionary statements have been changed to match those of the adopted UN Globally Harmonized System (GHS).
ASW, also known as refractory ceramic fibre (RCF), has been classified in 1997 as a carcinogen category 2 - "Substances that should be regarded as if they are carcinogenic to human" under the Dangerous Substances Directive; translated under CLP Regulation into carcinogen category 1B "Presumed to have carcinogenic potential for humans, classification is largely based on animal evidence".
ASW is listed under EU index number 650-017-00-8 in Annex VI part 3 table 3.1 of CLP (replacing Annex 1 of the Dangerous Substances Directive) which specifies the information required on the labels.
Special labelling obligations exist for ASW/RCF substances and for mixtures if they contain 0.1% by weight of the substance.
AES wools produced by ECFIA members have been exempted from classification after scientific assessment. They fulfill the Exoneration Criteria of Note Q of the European Dangerous Substances Directive based on biopersistence tests or long-term animal studies. (See Annex VI part 3 table 3.1 of CLP, EU index number 650-016-00-2.)
Labelling is not required under CLP.
PCW are not classified under CLP and labelling is not required.
In Germany, TRGS documents provide technical guidance on worker protection. TRGS 905 considers some inorganic fibrous work place dust as carcinogenic, mutagenic or toxic for reproduction. Fibrous dusts emanating from the handling of polycrystalline wools are classified as Category K3: " ... cause concern for man owing to possible carcinogenic effects but in respect of which the available information is not adequate for making a satisfactory assessment ... " Although the TRGSs are not laws they are technical rules/recommendations with a quasi-legal status.