Notification to the C&L Inventory
Manufacturers and importers are required to notify the European Chemicals Agency (ECHA) of the classification and labelling of hazardous substance(s) placed on the market, and of substances which are placed on the market and subject to registration in accordance with the REACH Regulation. Only representatives already appointed for the purposes of REACH registration may submit a group notification on behalf of EU importers, but cannot take over the obligations of the importers that are part of the group. The information to be notified includes:
a) Identity of the notifier placing the substance or substance in a mixture on the market
b) Identity of the substance(s)
c) Classification of the substance(s)
d) Where a hazard class is not classified, the notifier must indicate justification (e.g. lack of information)
e) Specific concentration limits or M-factors, where applicable
f) The label elements and any supplemental hazard statements
The ECHA will then include the information in a database, known as the classification and labelling (C&L) inventory. Substances placed on the market on or after 1 December 2010 require notification within one month after their placing on the market. There is no need to notify the substance if the same information has already been submitted as part of a registration under REACH by the same actor. Further guidance on what should be included in a notification and how to do it is available on the ECHA website.
The C&L Inventory
The ECHA maintain a database of the classification and labelling elements of all substances notified or submitted as part of REACH registration dossiers. The database indicates if there is a harmonised classification for an entry, or if it is an agreed entry between notifiers or registrants. Publication of the C&L Inventory helps achieve much needed transparency on the physical, health and environmental hazards of commonly used chemicals within the EU. It is the largest database of its kind globally and it is widely anticipated that it will help improve the safe use of hazardous chemicals for both workers and consumers alike. The C&L Inventory is available publically here.
Several different classifications for the same substance may exist in the C&L Inventory. This may be due to legitimate reasons such as different compositions or impurity profiles, however notifiers or registrants may have arrived at different classifications using the CLP criteria. Where several classifications exist for the same substance, the number of notifiers reporting each classification, and whether the classification was as a result of joint submission under REACH registration will be displayed in the C&L Inventory. The HSA encourages Irish companies to use the data in the C&L Inventory, as a common ground, to reach agreement on the self-classification and labelling of hazardous substances and subsequently the products these substances are used in. The ECHA have established a web-based discussion forum, known as the C&L Platform, to assist registrants and notifiers of substances in the agreement of entries to be included in the C&L Inventory.
The Classification and Labelling Platform
The C&L Platform provides notifiers and registrants with a forum to contact each other and discuss the appropriate classification and labelling of their substances, in order to best fulfil Article 41 of the CLP Regulation; “...where the notifications of classification and labelling to the C&L Inventory result in different entries for the same substance, the notifiers and registrants shall make every effort to come to an agreed entry to be included in the inventory…”. Information on how to access and use the C&L Platform is available on the ECHA website.
Notification to the C&L Inventory Guidance:
ECHA: How to Notify Substances to the C&L Inventory
ECHA: C&L Platform