Do you import any chemical substance or mixture from outside the EU (incl. Great Britain)?
An importer is any EU-based company/legal person that imports a chemical substance or mixture from outside the EU, including imports from Great Britain.
Do you import more than one tonne per year of the substance collectively across imported substances and mixtures?
Importers of chemical substances on their own and in mixtures from outside the EU in quantities of one tonne or more per year, must register such substances with the European Chemicals Agency in accordance with REACH. Importers of a substance below the one tonne threshold do not require REACH registration.
Have you checked whether classification applies to the imported chemicals?
Regardless of tonnage, import is considered as ‘placing on the market’ therefore importers must determine whether classification applies based on the criteria set out in the CLP Regulation. Where classification is required, importers must classify, label and package in accordance with the CLP Regulation and notify to the classification and labelling inventory at ECHA.
Have you determined whether a safety data sheet is required?
If the substance or mixture is classified in any hazard class (physical, health or environment) in accordance with CLP and/or is included on the candidate list the importer must compile and provide a safety data sheet. If the mixture contains ≥ 1% (0.2% for gaseous) of a substance posing a health or environmental hazard, or ≥ 0.1% of a CMR, PBT or vPvB substance or contains a substance that has an occupational exposure limit value, the safety data sheet should be available on request.
If a safety data sheet is not required, the recipient should still receive information on registration, authorisation, restriction and risk management measures.
Have you determined whether notification to the National Poison Centre is required?
Importers of hazardous (health and/or physical endpoint classifications) mixtures placed on the Irish market must notify the National Poison Information Centre (NPIC) and include their emergency telephone number in Section 1.4 of the safety data sheet.
Please note that all EU poison centres will be harmonised and information for professional and consumer uses can be submitted to the Poison Centre Notification (PCN) portal from 1st January 2021, which will include the generation of a Unique Formula Identifier (UFI) for inclusion on the label and safety data sheet. Industrial uses must be notified to the PCN portal from 1st January 2024 and until that time should be submitted as normal to NPIC. If you have notified to the National Poison Centre before 1st January 2021 you may benefit from a transitional period before notifying to the PCN until 1st January 2025.
Have you checked whether the substance is subject to Authorisation?
Substances listed on Annex XIV (Authorisation List) may only be imported after the substance’s ‘sunset date’ if an Authorisation has been granted by ECHA.
Have you checked whether the substance is subject to Restriction?
Certain substances listed on Annex XVII (Restriction List) may be restricted from import or ‘placing on the market’.
Have you checked whether the substance is subject to the PIC Regulation?
Importers of substances on their own or in mixtures from outside the EU, that are listed on Annex I of the PIC Regulation (EC) No.649/2012 must submit annual tonnage information by 31st March of the following year. You can check whether your substance is listed by checking on ECHAs website and reading further information here.
Is the product you are importing a detergent?
Detergents must comply with the additional, specific labelling and packaging requirements outlined in the Detergents Regulation (EC) No. 648/2004 and on our website.