Classification and Labelling Inventory
The Classification & Labelling (C&L) Inventory is available from the ECHA website. It is a database containing information on the hazards of more than 115,000 substances available on the EU market. The information has been received by ECHA through over 3.5 million submissions made by the European chemicals industry, including many Irish companies.
The recent publication of this C&L Inventory helps achieve the 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 its publication will help improve the safe use of hazardous chemicals for both workers and consumer alike.
What is the classification and labelling inventory?
The C&L inventory is a database established and maintained by ECHA, which contains basic classification and labelling information on notified and registered substances. It also contains the list of harmonised classifications (Annex VI).
Manufacturers and importers are obliged to notify the classification and labelling information for their substances, which are placed on the market and are within the scope of CLP i.e. classified as hazardous, either on their own or in a hazardous mixture, regardless of tonnage, within one month of placing on the EU market. In addition, substances subject to REACH must also be notified. If the classification and labelling information has already been sent to ECHA as part of a full registration in accordance with REACH, it does not need to be notified again.
How do I notify my substance to the C&L Inventory?
Please note that before you submit your notification you need to set up a REACH-IT account.
For further information on how to do this please review ECHA’s Industry User Manual on ‘How to get started with REACH-IT’ and ‘Sign-up and account management’. Notifications can be done using one of the three notification tools provided by ECHA, depending on what your needs are. These tools are:
- Online REACH-IT: this will allow you submitting your notification online directly in REACH-IT. A useful feature of this tool is that if your substance is listed in Annex VI to CLP, by inserting either the CAS or the EC number of your substance, the Classification and Labelling elements will be automatically filled in by the tool and you will only have to press the “I agree” option.
- Bulk XML: this tool will be useful in those cases when you need to submit several notifications. It will allow you preparing your notifications offline and then submit them in “bulk” in XML format. You need an IT-background in order to work directly in XML; however, an Excel macro-enabled version is also available, which will convert in XML format automatically. The tool is applicable only to substances with an EC or CAS number and with only one composition and one C&L.
- IUCLID 5.2: this is the only tool you can use if you want to specify multiple compositions for your substance. In addition, the further actions are also to be performed uniquely by this tool:
- Claim confidentiality;
- Set your own Specific Concentration Limits (SCLs), if not agreeing with those already set in Annex VI to CLP for your substance, and provide a scientific justification for that;
- Set your own Classification and Labelling elements, if not agreeing with those already set in Annex VI to CLP for your substance, and provide a scientific justification for that;
Please note that the Bulk XML and IUCLID 5 tool will only help you in creating a notification dossier for your substance. You will still need to submit your dossier by uploading it via REACH-IT.
How will the C&L Inventory show differing C&L for the same substance?
In the C&L Inventory the notifications for the same substance are grouped together based on their numerical identifiers. This means that different classifications and labellings for the same substance will be visible if different notifiers or registrants have arrived at different classifications of the substance by applying the classification rules in CLP.
If a harmonised classification and labelling according to CLP criteria (Table 3.1 of Annex VI to the CLP Regulation) for that substance exists, it is displayed above the notifications.
If there are several notifications which classify the same substance in the same way they are merged and the number of notifiers behind each aggregated classification is indicated. The aggregated display will contain all classification and labelling elements, except for the reason for non-classification and the physical state/form of the substance.
In addition to indicating the number of notifiers behind each aggregated notification, the C&L inventory also indicates whether classifications are derived from a jointly submitted REACH registration dossier.
The aggregation is done automatically, without manual verification by ECHA. Technical or clerical errors when notifying may thus result in different entries displayed.
In accordance with Article 41 of the CLP Regulation, notifiers should make every effort to come to an agreement on the classification of their substances. However, there can be legitimate reasons for different classifications, such as different compositions or impurity profiles.
The HSA encourages Irish companies to use the data in this 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. For a brief overview of the classification and labelling notification duties under the CLP Regulation, please visit the dedicated ECHA webpage. Furthermore, ECHA has published a practical guide on how to notify substance in the Classification and Labelling Inventory and a Technical Frequently Asked Questions document on C&L Notifications.
Further Information on C&L Inventory