Notification to the Classification and Labelling (C&L) Inventory Services

Notification to the Classification and Labelling (C&L) Inventory is regulated under Article 40 of the CLP Regulation (EC) No. 1272/2008 on the classification, labelling, and packaging of substances and mixtures.

To maintain regulatory compliance on the EU markets, enterprises need to fulfill the C&L notification obligation once the substance and the role in the supply chain are in the scope of the CLP Regulation.

Chementors offers C&L inventory notification service. We handle the task from scratch. Each step in the process is made following the relevant terms and conditions of the CLP Regulation. By this, we confidently guarantee compliance with the Regulation. Please contact our experts for more details.

C&L Inventory

C&L Inventory is a database collecting classification and labelling information on notified and registered substances submitted by manufacturers and importers.

Managed by the European Chemicals Agency (ECHA), this public database provides a comprehensive and open source of information on how a particular substance is identified, classified, and labelled, including harmonized classifications, in the EU.

This forms an open and effective communication platform between businesses, authorities, and the public.

The hazard information on the C&L Inventory would eventually help manage the risks and improve the safety of workers, consumers, and the environment as well as support authorities on the decision-making process.

Scope of Notification to C&L Inventory

What kind of substances are subject to the notification obligation?

According to Article 40 of the CLP regulation, the following substances must be notified to the C&L Inventory within one month from being placed on the market regardless of the annual quantities:

Substances that are subject to registration under the REACH Regulation (EC) No. 1907/2006 and placed on the market. This includes substances on their own or in mixtures, and certain substances contained in articles regardless of whether they are hazardous or not.
Substances that are classified as hazardous under CLP regulation and placed on the market either on their own or in a mixture above the specified concentration limits.

According to CLP Article 40, the notification responsibility is on:

the manufacturers and importers of substances that are subject to registration under the REACH regulation
Importers of mixtures containing substances that are classified as hazardous and are present above the relevant concentration limit
Importers of articles containing substances that are subject to registration under the REACH Regulation.

In case the non-EU suppliers or manufacturers do not want to provide composition information of their substances or mixtures to the EU importers for C&L Inventory notification purposes, they can appoint an EU-based Only Representative to submit the notification dossier to the C&L Inventory.

Information for the notification dossier

A C&L Inventory notification dossier should include the following information:

Details of the notifier i.e., name, address, contact person.
Identification information of the substance i.e., name and other identifiers, molecular information, structural formula, composition, nature, and quantity of additives
Hazard classification of the substance according to the CLP regulation
Reason for “no classification” if the substance is classified in several but not all hazard classes or differentiations indicating whether this is because of
- a lack of data,
- inconclusive data, or
- data that is conclusive for non-classification
Specific concentration limits or M-factors, where relevant, including a justification for setting them; and
Label elements i.e., hazard pictograms, signal words, hazard statements, as well as any supplemental hazard statements.

Our Expertise in the C&L Inventory notification process

We have extensive experience in handling the C&L Inventory notification process in compliance with the CLP regulation. We work closely with our clients to ensure that all necessary data is gathered, and the notification is submitted on time.

Our expertise in C&L Inventory notification includes:

Data collection

collecting required data from different actors in the supply chain to make sure that all relevant information is available. Consulting and supporting the client in gathering missing information.

Data assessment

evaluating the dataset to ensure data accuracy and consistency.

Regulatory compliance

conducting the C&L inventory notification following relevant terms and conditions set out in the Regulations

Following up after submission

managing the submission status and acting promptly toward notifications and requirements from the authorities.

Our C&L Inventory Notification Services

We offer a full C&L Inventory notification service from scratch to help businesses comply with the relevant Regulations.

Our C&L Inventory notification process involves the following steps:

Understanding the project needs including compliance status of the substance and expected timeline
Gathering required data
Planning to fulfill missing data including data search and lab test
Compiling the notification dossier
Submitting the notification dossier to ECHA system
Following up on ECHA’s decisions

With Chementors, you can rest assured that you are always complying with the highest standards and best EU REACH practices.

Contact us for your REACH NEEDS

FAQs

Are only substances manufactured or imported in quantities of over one tonne required to be notified to the C&L Inventory?

No, the C&L notification obligation is applied to substances that meet certain criteria, as described above, regardless of the annual quantities.

How is the one-month deadline for notification to the Classification and Labelling Inventory calculated?

According to the Regulation, the notification must be done within one month after the substance is placed on the EU market. This obligatory one-month deadline is calculated from the first date a substance is placed on the market.

How long does the notification to the Classification and Labelling take?

Once all the required information is made available to Chementors, generally it takes around 5 to 7 hours for dossier preparation and submission. The submission outcome depends on ECHA’s workload and decision.
It would take a bit longer time if there is missing information. Therefore, we highly recommend enterprises proceed with the task as soon as possible to have sufficient time for fulfilling the missing data.