What is the C&L Inventory?
The Classification and Labelling (C&L) Inventory is a database maintained by ECHA, containing information on the classification and labelling of substances. It is freely accessible and provides insight into the (various) classifications of the same substance applied by different (groups of) suppliers. It further contains the list of legally binding harmonised classifications, in accordance to CLP Annex VI. It is therefore a useful tool in the process of performing SDS checks.
Who must notify to the C&L Inventory?
You must notify your substance in the following situations:
- Your substance is subject to REACH registration (unless the manufacturer, importer or Only Representative (OR) has already submitted the information on classification and labelling to ECHA as part of a REACH registration, or if it has already been notified by that notifier).
- The substance you place on the market* is classified as hazardous under CLP. In this case, your obligation to notify the substance is irrespective of tonnage.
- The substance is classified as hazardous under CLP and is present in a mixture in a concentration above the threshold limits for mixture classification (causing the mixture you place on the market to be classified as hazardous).
* “Placing a substance or mixture on the market” is defined under CLP as: supplying or making the substance or mixture available to third parties, whether in return for payment or free of charge within the territory of the EU Member States and those EEA countries which have implemented the CLP Regulation. In addition, import is deemed placement on the market.
In short, only manufacturers of substances and importers of substances or mixtures have the obligation to notify. Downstream users need not notify to the C&L Inventory, but may need to notify to the Poison Centre.
Substances meeting the abovementioned must be notified within one month from being placed on the market. The Chemical Compliance Coach can assist you in the preparation of the notification in IUCLID 6, and its submission via REACH-IT.