Compliance and safety for the supply of chemical products
CLASSIFICATION
Classification and labelling inventory - Our services
All EU importers of chemical products from outside of the EU, or EU-based manufacturers, have to notify the classification of the substances to the Classification and Labelling Inventory (C&L Inventory; EU Regulation 1272/2008, Chapter 2).
This requirement applies to the substances fulfilling the following criteria for supply:
- Subject to REACH registration, which includes most substances that are supplied at greater than 1 tonne per year, whether or not classified as hazardous
- All substances that are classified as hazardous and supplied neat, plus those that are present in mixtures at a concentration high enough to require classification of the mixture, in both cases with no lower tonnage threshold
If the importers do not make the notifications, then they may be prevented from importing the substances, whether neat or in formulations.
- Deadline for notification: within one month of first importation
This obligation is separate from the obligation to register substances under the REACH Regulation, although if the manufacturer/importer has already registered the substances under REACH, then the obligation to notify to the CLP Inventory is considered to be fulfilled.
A non-EU supplier can help their EU importers by organising one importer to make the substance notifications on behalf of all their importers. It is not the usual job of the REACH Only Representative (OR) to make the notifications. In fact, the OR can fulfil this role only if they are supplied with a sample of the substance, thus in effect becoming an importer.
Alchemy Compliance offers the following service to suppliers of chemical products:
- A check of the hazard classification
- Notification of your substances to the EU C&L inventory, on your behalf or that of your EU-based importers, via the ECHA web portal.
Further information
The notification to the C&L Inventory requires detailed information:
- Identity of the notifiers (ie the manufacturer, importer, or group of these)
- Identity of the substance, including purity/impurity profile
- Classification, plus the M-factor if applicable (see CLP classification), and any special concentration limits for classifying mixtures
- Label elements (hazard pictograms, signal word, hazard phrases, and supplementary hazard statements)
Many of the entries on the classification and labelling inventory will be the result of REACH registrations, which include information on the classification and labelling. As noted above, if the REACH registration has been completed, then notification to the C&L inventory is not required. Importer/manufacturers will need to make separate C&L notifications if they are registering phase-in substances under REACH at one of the later deadlines (2013 or 2018, see REACH Summary), or if they are manufacturing/importing any hazardous substance, or importing a mixture containing a hazardous substance above the threshold that causes the mixture to be classified. Thus, nearly all substances will require notification to the C&L inventory, with the exception of:
- non-hazardous substances or ingredients manufactured/imported below 1 tonne per year
- hazardous ingredients in mixtures that total less than 1 tonne per year, and are present in the mixture at a concentration low enough that the mixture is not classified
The notified classification and labelling will be made public in a database. The Commission stipulates that where notifiers give different classifications for the same substance, then the notifiers (or REACH registrants) will make ‘every effort’ to come to an agreed entry.
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