Hazardous substances such as UVCB petroleum substances and sulfur are subject to the CLP notification requirement.
Articles 39 – 42 of the CLP Regulation (EC) No 1272/2008 require manufacturers and importers to notify the classification and labelling of hazardous substances (as such, in mixtures or in articles subject to REACH Article 7 registration requirement) irrespective of the volume of the substance. The notification is required within one month after placing the substance on the market.
Hazardous substances already REACH registered by the same Legal Entity do not need a CLP notification. This obligation is then covered by the Lead Registrant in the joint registration submission.
The notification is required in a specified format. In practice, companies can make their notification either online via REACH-IT or in IUCLID format (for more complex cases, like several compositions for one substance).
CLP notifications need to be updated according to the latest legislation developments (ATPs to CLP).
Useful links are provided below:
- Concawe petroleum substances inventory
- Concawe Report Classification and Labelling of petroleum substances
- Contact for further inquiries: firstname.lastname@example.org or email@example.com
Supporting Guidance on the ECHA Website:
- Who has to submit and what can be submitted in a notification?
- How to submit and update your C&L notification
- ECHA Q&As