In order to facilitate harmonized entries for petroleum substances and sulfur in the CLP inventory, Concawe is providing IUCLID CLP notification files, consisting of Sections 1.1 (Substance identifiers) and 2.1 (CLP/GHS classification) that can be used for the notification of petroleum substances and sulfur under the CLP Regulation.
Legal Entities that needed to register under the REACH Regulation petroleum substances or sulfur before the 30 November 2010 deadline do not need to notify ECHA separately of the classification of their substances under the CLP Regulation. This obligation is covered by the information that the Lead Registrant submitted in the joint registration submission prior to 1 December 2010.
However, under the CLP Regulation, there was a need to notify ECHA by 3 January 2011 of the CLP classification for hazardous substances which are covered by REACH but exempted from registration (e.g. crude oil, LPG). Furthermore, for those Legal Entities having substances in lower tonnage bands and facing REACH registration deadlines only in 2013 or 2018 there was also a need to notify ECHA by the same deadline (3 January 2011) of the CLP classification of their substances which are subject to REACH. In addition, for substances not subject to REACH but which are placed on the market in quantities of less than 1 tonne/annum, the notification only applies to those substances which are classified as hazardous, and also should have been submitted by 3 January 2011. Hazardous substances imported as a component of a mixture in quantities of less than 1 t/a only need to be notified if they exceed CLP/DPD thresholds and the mixture is classified as hazardous.
Further information on the CLP Regulation can be found on the ECHA website.
ECHA’s C&L Platform
On 31 January 2013 ECHA launched a new on-line interactive communication tool, the Classification & Labelling (C&L) Platform, that allows registrants and notifiers of the same substance to fulfil their obligation to agree on a harmonised classification.
The C&L Platform is the easiest way to get in contact with companies that have submitted notifications or registrations for the same substance. Indeed, active use of the C&L Platform could speed up the process of agreeing on C&L for the same substance.
“Discussion features” are available in the C&L platform for each of the substances for which there are different entries in ECHA’s C&L inventory web pages. Access to and participation in the discussion rooms on substances is simple, quick and easy (though each discussion room is accessible only to registrants and notifiers for that particular substance).
ECHA’s intention is that the C&L Platform will be used to facilitate compliance with the CLP Regulation and to improve the overall quality of the public C&L Inventory data. It will also be beneficial for SMEs, as they will be able to follow the classifications set by larger companies.
The C&L Platform can be accessed through the C&L Inventory web page on the ECHA website. Users need to have a valid REACH-IT account to access the platform and ECHA’s website provides more detailed information on how to log in, access and utilise the platform, including a Q&A and User Manual.
CLP Notification Files
Concawe has prepared CLP Notification files in IUCLID6 format. These files incorporate the latest Adaptations to Technical Progress (ATP) to the CLP Regulation.
For each substance listed in the Concawe inventory, there is an IUCLID file, named eee-eee-e Concawe CLPNotification.i6z where eee-eee-e is the EC number of the substance (click here for files) except for Petroleum Coke (exempted from REACH and not classified). Use the Concawe inventory to find the substance identifier (EC number) of the substance to be notified
Companies having submitted CLP notification file(s) should update their CLP notification dossier(s). This requires that the updated Concawe CLP notification files are first implemented into the registrant’s IUCLID6 instance(s) and then used to create new CLP notification dossiers.
A summary of instructions can be downloaded here.
For Concawe’s recommendations on Classification and Labelling, please see Concawe Report 9/15.
For more information send an email.