CLP Notification

In order to facilitate harmonized entries for petroleum substances and sulfur in the CLP inventory, CONCAWE is providing IUCLID5 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 here.

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

As of 13 April 2011, REACH-IT only accepts submissions using IUCLID5.3.0. CONCAWE has migrated the earlier set of CLP notification files to IUCLID5.3.0. The migration has also incorporated corrections to IUCLID5 Section 2.1.

There is a .zip file for each substance listed in the CONCAWE inventory (click here for files) except for Petroleum Coke (exempted from REACH and not classified). Use the CONCAWE inventory to find the substance identifiers (EC number, CAS number) of the substance to be notified.

Please note that the CLP notification files for petroleum gases have been prepared by the Lower Olefins and Aromatics Services Team (LOAT). Should you have any queries regarding the content of the CLP notification files for petroleum gases, please contact them via the enquiry form on the LOA REACH Consortium website.

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 IUCLID5.3.0 instance(s) and then used to create new CLP notification dossiers (note that the “old” CLP notification dossiers cannot be changed and will remain forever in IUCLID5.2.x format).

Please click here for an information package containing:

  • A document Guidance for migrating IUCLID5 instances to IUCLID530 20110426.ppt which summarizes the procedures to migrate IUCLID data to IUCLID5.3.0
  • A webinar Webinar for migrating IUCLID5 instances to IUCLID530 20110426.wrf which demonstrates the procedures to migrate IUCLID data to IUCLID5.3.0
  • A document Guidance for CLP notifications under IUCLID530 20110426.ppt which summarizes the procedures to carry out CLP notifications under IUCLID5.3.0
  • A webinar Webinar for CLP notifications under IUCLID530 20110426.wrf which demonstrates the procedures to carry out CLP notifications under IUCLID5.3.0
  • A file CLP Notification files Summary of IUCLID5 section 2.1 changes.xls which describes the changes made to the CONCAWE CLP notification files
[Note: For optimal performance, we suggest the use of headphones or external speakers when listening to the webinars.]

Further information on the use of IUCLID can be found on the European Commission website at: http://iuclid.eu

For Concawe’s recommendations on Classification and Labelling, please see: Concawe Report No. 9/15

For more information send an email.