The C&L inventory is a database managed by ECHA which contains information on classification and labelling of substances placed on the European market. This database includes information on notified and registered substances but also the list of harmonised classifications and labelling according to Annex VI CLP.
In the context of the C&L inventory, manufacturers and importers must notify the classification for all substances placed on the market.
A notification to ECHA must be done when:
- Manufactured and/or imported substances are subject to registration according to the REACH Regulation;
- Substances are classified as hazardous;
- Mixtures containing a substance that is classified as hazardous and is present above the relevant concentration limit, which results in the classification of the mixture as hazardous;
- Articles containing a substance which is subject to registration under Article 7 of the REACH Regulation.
The notification must be done within one month of placing the substance on the market. For importers, the one month timespan is counted from the day when a substance, on its own or contained in a mixture, is physically introduced into the customs territory of the European Union.
- There is no exemption for C&L notifications, thus even substances exempt under the REACH Regulation must be notified.
- If a manufacturer or an importer has already submitted a registration dossier under REACH for a substance he does not have to submit a separate C&L notification because the information requested for the notification have already been provided in the registration dossier.
How to notify?
The C&L notification can only be submitted electronically through the REACH-IT portal on the ECHA website.
There are three ways to submit a notification:
- Online by using REACH-IT, or
- Create a IUCLID dossier and then submit the notification via REACH-IT, or
- Submit a bulk notification, by uploading in REACH-IT a XML bulk file.
Confidentiality of IUPAC name
Companies may, under certain conditions, keep the IUPAC name of a substance confidential when notifying it to the C&L Inventory. The IUPAC name can be considered confidential and is therefore not published in the C&L inventory for:
- Non-phase-in substances;
- Substances only used as one or more of the following:
o In scientific research and development,
o In product and process-orientated research and development.
Only IUCLID can be used to make such confidentiality flags. There is no fee for the confidentiality flags in the C&L notification.
Information in the C&L inventory
The following information is published according to CLP (Article 42):
- The name in the IUPAC nomenclature for substances classified with certain hazard classes or categories set out in Article 119(1)(a), without prejudice to Article 119(2)(f) and (g) of REACH;
- The name of the substance as given in EINECS, if applicable, and other numerical identifiers as appropriate and available;
- The classification and labelling of the substance.
All notifications for any published substance are included in the C&L Inventory and this includes notifications for non-classified substances.
- Introductory Guidance on the CLP Regulation (section 17)
- Factsheet on the public inventory
- ECHA webpage on C&L inventory
- ECHA’s Q&As on C&L inventory