Each notification should include:
- Name and contact details of the notifier;
- Identity of the substance, including name and other identifiers, information related to molecular and structural formula, composition, nature and amount of additives;
- Classification of the substance according to the CLP criteria;
- Reason for "no classification" in case the substance is classified in some but not all hazard classes or differentiations indicating whether this is due to
- lack of data,
- inconclusive data, or
- data which is conclusive for non-classification;
- Specific concentration limits or M-factors, where relevant, including a justification for setting them; and
- Label elements, including hazard pictograms, signal words, hazard statements and any supplemental hazard statements.
Confidentiality of IUPAC names
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 therefore not published in the C&L inventory in the following cases:
- non-phase-in substances;
- substances only used as one or more of the following:
- as intermediates;
- in scientific research and development; or
- in product and process orientated research and development.
To keep the IUPAC name confidential, companies need to provide in their IUCLID dossier:
- A justification including a clear indication whether the substance concerned is a non-phase-in substance, a substance used as a chemical intermediate, in scientific research and development or in product and process orientated research and development.
- An alternative name for dissemination by ECHA.
Only IUCLID 5 can be used to make such confidentiality flags, how to do this is explained in the Data Submission Manual Part 12.
There is no fee for the confidentiality flags in the C&L notification.
An alternative name provided in a C&L notification for dissemination cannot be used automatically for other purposes. An appropriate request is needed in order to use an alternative name for a substance in a mixture in a Safety Data Sheet or on a label.
- Practical guide 7: How to Notify Substances to the Classification & Labelling Inventory [PDF]
- Introductory Guidance on the CLP Regulation [PDF]
- Guidance on the Application of the CLP Criteria [PDF]
- FAQ on Classification and Labelling [PDF]
- Q&A on Classification and Labelling [PDF]
- Table 3.1 of Annex VI to CLP contains the harmonised classification and labelling [PDF]
- Data Submission Manual Part 12: How to prepare and submit a C&L notification using IUCLID [PDF]
- Derivation of alternative names under Directive 1999/45/EC: Directive 1999/45/EC, Annex VI, part B [PDF]