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How to submit a CLP Notification

This page provides information on how to submit a CLP Notification. An introduction to CLP can be found here. Further information on the Classification and Labelling Inventory can be found here.

How can I submit a notification?

Notifications can be submitted either individually by companies, or together by a group of companies. Groups of companies submitting a notification will need to agree on a classification for their substance.  The most straightforward groups will be those containing members of a SIEF who do not need to register until 2013 or 2018. Such groups already have the mechanisms in place to contact each other and agree a classification. However, CLP does not limit group notifications to SIEFs and other groups may also be created, for example members of a trade association, manufacturers and importers with tonnages below the REACH registration threshold, etc. Although the notification is submitted as a group, each member remains responsible for their own notification – if anything changes the individual company is still responsible for updating their notification. ECHA also recommends that groups document their agreement with the classification decision – depending on the size of the group, this could be by email, electronic survey, etc.

 

Notification needs to be made through the REACH-IT portal, so if a company does not already have a REACH-IT account the first step is to create one. The portal can be accessed at https://reach-it.echa.europa.eu/reach/public/welcome.faces

 

Companies then have several options for how to make their notification submission:

 

  • IUCLID 5 -  Companies may want to use this tool if they are familiar with the system and/or are preparing a registration dossier for a later date. IUCLID 5 is the only way to submit a notification if you have more than one classification for a substance. For example, a metal in powdered form may have different hazards to the same substance in massive form, such as flammability. Substances with different compositions, for example a substance manufactured at several different sites with different impurity profiles, may also have more than one classification. Again IUCLID 5 must be used in such cases, as this tool can be used to store information on multiple compositions and the classification and labelling associated with each one.

  • Bulk Notification Tool - Allows you to create a submission file for multiple substances, which is useful if you have a lot of notifications to make. This tool is good for large companies who have some or all of the necessary information already stored in their in-house IT system.  Two versions of the tool are available – a MS Excel based spreadsheet, or an XML schema for those with suitable IT expertise available. The Bulk Notification Tool can only be used for substances that have either an EC no or CAS no, and have only a single classification.

  • On-line notification tool – This tool aims to help SMEs through the notification process, especially where companies have only a few substances to notify, and are not familiar with IUCLID. The tool flows logically through the process and there are plenty of helpful tool tips and explanations to guide the user in completing the forms. A further benefit of the on-line notification system is that if there is a harmonised classification, or if someone else has already submitted a notification for the same substance, the user can simply say “I agree” with the one of the existing notifications and they will not have to fill out any further classification information. This will clearly ,make life much easier for companies with only small quantities and limited resources, however, it may result in a cat and mouse game of waiting for another company to make the first classification. The On-lineTool can only be used for substances that have only a single classification

  • Group Creator Tool - An MS Excel based is also available to help companies gather the necessary data from other companies who wish to join together with them to submit a group notification.

The Bulk Notification and Group Creator Tools can be downloaded from http://echa.europa.eu/clp/inventory_notification/tools_download_en.asp.

What information will I have to provide?

Whichever tool you use to submit your notification, you will need to provide at least the following information:

  • Your identity – Company details, contact details for a suitable person in the company, the compoany’s UUID in REACH-IT. If making a group notification, then this information will be required for each company in the group. This can be collected off-line using the Group Creator spreadsheet, and then uploaded, or the details for each company can be entered individually in the on-lone tool.
  • Substance identity – sufficient information needs to be provided to identify the substance.  This includes the information identified in REACH Annex VI 2.1- 2.3.4.  Analytical information is not required. Not all of this information may be available, and the minimum requirement is for the IUPAC name and the concentration range of the substance. Information on optical activity of the substance, if any, is also required.
  • Classification – either a classification decision or a reason for not classifiying must be recorded against each of the classification end points. In IUCLID 5 and the On-line tool, the default value “data lacking” is set for each end point. Other options are “inconclusive” where there is data but it is not sufficient to allow a classification decision to be made and the slightly oddly phrased “conclusive but not sufficient for classification” which means that there is sufficient data to decide that the substance is not classified as hazardous for that particular end point. If the substance is to be classified as hazardous for an endpoint, then the field “Reason for no classification” must be set to the blank entry before the hazard classification and hazard statement fields can be selected.
  • Specific concentration limits and/or M-factors. If these are added, then unless they have been set as part of a harmonised classification, a document giving a scientific justification for these values needs to be provided. It is recommended that this is provided using the relevant parts of the CSR template.
  • Precautionary Statements and Supplemental Hazard Statements may be provided but are optional.

Companies must update their notification as soon as possible if new information becomes available, e.g. as part of the REACH process.

To give an idea of resources needed for notification, then assuming that all the necessary data and documents have been gathered and the classification of the substance determined, then the notification process takes approximately 10-20 minutes to complete using the on-line tool. This is a little longer than REACH pre-registration, but is by no means as scary as some have predicted. Assembling the necessary information is of course the hardest part, and will vary depending on the substance. For a common substance with a reasonable amount of data available then this will probably take several hours. For substances with a very large amount of data, or with very little data, then it may take considerably longer.

For importers, then there may be issues in gathering the necessary data on substance identification from overseas suppliers.

Further information

A detailed list of of available guidance can be found at http://echa.europa.eu/help/help_docs_en.asp. The most useful of these are :

 

 

Two further documents expected to be available soon are:

·         Data Submission Manual part 13: How to prepare and submit a bulk C&L notification (bulk xml file)?

·         Industry User Manual part 16: How to do an online submission to the C&L Inventory

 

This page last updated 11 June 2010