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Selling your chemical products on the European market? Don't forget the C&L inventory!

That labels of consumer chemical products such as detergents and air fresheners must meet strict legal requirements is probably not unknown to you. That in many cases these products must be registered with national antitoxin centers (and in time with the new European antitoxin center) many companies also know. More and more companies now also know that they must register substances if they produce or import more than 1000 kg per year. But did you know that there is another notification you must take care of if you sell chemical products on the European market?

The European classification and labeling inventory: the C&L inventory

The C&L inventory is a public database containing hazard classification information on substances placed on the European market. This information comes, among other things, from the CLP regulation (the harmonized classification of the substance in question) and existing REACH registrations.

Even if you are not required to register a substance, you often do have an obligation to report information about the hazard classification of the substances you use to ECHA. You must submit a C&L notification for this purpose.

When is a C&L notification required?

If you sell consumer chemical products on the European market, you are required to submit a C&L notification to ECHA if you:

  • Imports a chemical substance for more than 1000 kg and must register it according to the REACH regulation
  • Imports a chemical substance for more than 1000 kg and must register it according to the REACH regulation
  • Imports a mixture that contains substances classified by themselves as hazardous according to the criteria in the CLP regulation and is present in such high concentrations that the complete mixture is classified as hazardous

This means that importers of consumer chemical products classified as hazardous under the CLP regulation must also submit a C&L notification for the substances that contributed to this hazard classification.

What information should a C&L notification contain?

If you import consumer chemical products classified in one or more hazard categories, submit a notification for each hazardous substance. This notification shall include at least the following information:

  • the name and contact information of the notifier
  • substance identity, such as:
    • o de stofnaam en andere identificatiegegevens
      o informatie over de moleculaire en structurele formule
      o de stofsamenstelling
      o de gebruikte additieven
  • information on any contaminants
  • the classification of the substance according to the criteria in the CLP regulation
  • specific concentration limits or multiplying factors referred to in Article 10 of the CLP Regulation, if applicable
  • the applicable labeling elements, such as:
    • o gevarenpictogram(men)
      o signaalwoord
      o gevarenaanduiding(en)
      o eventuele aanvullende informatie over de betreffende gevaren

    A notification must be submitted no later than one month after you place your product on the European market.

    Need support?

    Do you use substances classified as hazardous in your products and need to submit a notification to ECHA? Précon Quality Services can support you with this! Feel free to contact us at +31 (0)30 - 65 66 010 or info@precongroup.com.

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