The Classification & Labelling (C&L) Inventory is an attempt to collate the proposed classifications of hazardous or high volume substances manufactured or imported into Europe.
Firstly, it is important to note that the C&L Inventory does not cover every substance on the European market, only those for which notification to the C&L Inventory is required. The published C&L Inventory includes:
Substances for which a harmonised classification has been agreed – this may be a full classification for all hazard endpoints for the substance, or may only cover some hazard endpoints, and self-classification by suppliers for all other endpoints will be required;
Substances which have been registered under REACH;
Other hazardous substances which are below the REACH registration threshold, whether manufactured or imported alone as a substance, or as part of a hazardous mixture.
Registered substances which do not meet the criteria of the amended Article 119(1), i.e. substances which are not classified as hazardous for any of the specified endpoints were not included in the first version of the C&L Inventory, but later versions now include non-hazardous substance entries. Information on the classification of registered substances can also be obtained using the disseminated database of registered substances, also available through the ECHA website.
Not included in the C&L Inventory are substances not classified as hazardous which are manufactured or imported below the REACH registration threshold of 1 tonne per year, as these need not be notified to the C&L Inventory.
The C&L Inventory will also not provide information on the classification and labelling of formulated mixtures, i.e. mixtures created where two or more substances are deliberately mixed together.
Using the C&L Inventory
When searching the Inventory, it is likely that the user will find multiple classifications for the same substance.
In some cases this may be justified, due to the substance being placed on the market with different impurities that affect classification, or in different physical states.
In many cases though, differences in classification are due to users having different sets of data on which to base their classification, or simply making errors in assigning classifications, and label elements.
So how should the C&L Inventory be used? The answer is with caution. Be wary of taking the easy routes, such as
- Agreeing with the majority – there is no guarantee that they are correct, and they are often wrong
- Agreeing with the most severe hazard classification – this may be the safe option for lawyers, but is scientifically invalid and may cause many problems for suppliers and their customers
- Agreeing with the least strict – this may be tempting, but you need to be confident of the classification before doing so.
So what then is the answer? Firstly, it is a good idea to look for 'joint entries' that indicates information from registration dossiers and then perhaps to check back by viewing the disseminated dossiers. Where a substance has a well known name or identification number it may be easier to use the search function on the ECHA homepage which searches across all the various ECHA databases, including both the disseminated dossiers and the C&L Inventory, rather than using the more specific search tools on the C&L Inventory page.
You also need to go back to basics and check other information sources such as ESIS and other national data bases (the eChemPortal site is useful for this), searching other SDS, and using your skills to gauge the suitability and reliability of the classifications based on this available data.
As time goes by, and more substances are registered through the REACH process, and groups of manufacturers and importers come together to agree classifications, the quality of information in the C&L Inventory is expected to improve. Until then the C&L Inventory is only one more tool and is not the complete answer.