Notification C&L

You must notify a substance to the Classification and Labelling (C&L) Inventory within one month from being placed on the market and you:

• Manufacture the substance and it is subject to registration under the REACH Regulation; or
• Import the substance and it is subject to registration under the REACH Regulation; or
• Manufacture or import the substance and it is classified as hazardous, irrespective of the quantity; or
• Import a mixture which contains the substance that is classified as hazardous and is present above the relevant concentration limit, which results in the classification of the mixture as hazardous according to the CLP Regulation; or
• Import an article containing substances which are subject to registration under Article 7 of the REACH Regulation.

Only representative or importer – who should notify?

Only representatives (ORs) may submit the information needed for a notification to the C&L Inventory as part of a REACH registration dossier.

Where a separate notification to is necessary, the EU importers would normally have to submit the notification.

If, for reasons of confidentiality, non-EU producers do not want to disclose the composition of their substances or mixtures to their importers, they may appoint one of the importers in such a way that it also notifies them on behalf of the other importers (group notification).

Alternatively, a third party who is not in itself a producer or importer (eg an OR that has already been appointed for registration under REACH) may submit a group notification on behalf of importers. This person may submit the notification but can not assume the obligations of the importers.

If you use this solution, the applicant body must be able to document that it has acted on behalf of the producers / importers and they acknowledge that they remain solely and fully responsible for fulfilling all their obligations associated with the notification.

The documentation relating to the creation of this group of producers / importers, together with the data and information on which C & L is based, must be made available to the competent authorities and the competent enforcement authorities.