Safety data sheet knowledge base – Notification obligation to the classification and labelling inventory
Information on the identification, classification and labeling of the substance shall be notified to the Agency.
The CLP notification is free of charge and it is obligatory to notify within one month of placing the substance on the market.
Manufacturers and importers placing a substance on the market, in case one of the following criteria are met:
*You do not need to notify separately a substance you have already registered under REACH when the information to be notified has already been provided as part of the REACH registration dossier. This also applies to certain substances contained in articles where Article 7 of REACH provides for their registration.
If you are a downstream user who formulates a mixture, a distributor or a producer of articles, you do not need to notify to the Agency, because the notification for your substance already has occurred at an earlier stage in the supply chain.
There is also an obligation to update the information sent for notification.
In case you have new information that leads to a revision of the classification and labelling elements of a substance.
* Using the REACH-IT system, the range of data to be provided will be slightly different, and in practice, the process will look different.
The CLP Regulation actively engages the participants of the industries in identifying the hazard classes.
Of course, this may also mean that a substance is classified into several different hazard classes by individual notifiers.
In such a case the CLP Regulation orders the notifiers or registrants to make every effort to come to an agreed entry to be included in the inventory. However, you may classify your substance differently to another entry, provided you include the reasons in your notification.
In contrast, where your substance has a harmonised classification, you must classify it in accordance with the harmonised classification listed in Part 3 of Annex VI to CLP and include this classification in your notification.
Your notification must be in the format specified by the Agency. The notification dossier can either be created online by use of the REACH-IT tool or it can be created in IUCLID 6 (International Uniform Chemical Information Database).
The manufacturer, importer or downstream user may also make proposals to the Agency to change the classification of substances classified as carcinogenic, mutagenic or toxic for reproduction (CMR) or respiratory sensitization, if they can provide arguments justifying the need.
The classifications of all substances notified under CLP or registered under REACH are included (or will be included) in the classification and labelling inventory established at the Agency.
The inventory indicates whether a classification is harmonised or whether it has been agreed between two or more notifiers or registrants.
As a manufacturer of substances, an importer of substances or mixtures or as a downstream user, you need to assemble and keep available all the information that you used for the classification and labelling of your substance or mixture. This information must be kept for at least 10 years after you last supplied the substance or mixture.
As a distributor, you must in the same way assemble and keep available all the information that you used for the labelling.
The Competent Authority/ies or the enforcement authorities of the Member State where your company is established or ECHA may request all the information you used for the purpose of classification and labelling under CLP.
However, if the information requested by a Competent Authority is included in your notification under CLP, or your registration under REACH, this information will be available to ECHA, and the Competent Authority needs to address its request to ECHA.