Requesting an alternative chemical name in mixtures
Manufacturers, importers and downstream users based in the EU can submit a request for the use of an alternative chemical name to ECHA. It is not possible to appoint a ‘Third Party Representative’ or an ‘Only Representative’ to submit a request for use of an alternative chemical name in (a) mixture(s).
You must prepare your request with the latest version of IUCLID and submit it by using REACH-IT.
The ECHA Manual ‘How to prepare a request for use of an alternative chemical name for a substance in a mixture’ gives further instructions on how to prepare and submit the request.
Requests for the use of an alternative chemical name cannot be updated after their submission to ECHA, including the mixtures covered by that request, unless specifically requested by ECHA. Please always make sure that you include all relevant mixtures for which the alternative chemical name is to be used. Any later request for the use of the alternative chemical name in other mixtures will be a new request for which ECHA will levy another fee.
Preparing a request
1. Create your account in REACH-IT if you do not have one.
2. Create an alternative chemical name request dossier in IUCLID.
The following information is required to be included in the dossier:
- identity of the request submitter;
- the proposed alternative chemical name;
- identity and composition of the substance;
- information on the classification and labelling of the substance;
- the trade name(s) of the mixture(s) which contain the substance for which an alternative chemical name is requested;
- the SDS of the substance for which an alternative chemical name is requested;
- the SDS of the mixture(s) which contains the substance;
- a justification demonstrating that the request submitter has a commercial interest worthy of protection for non-disclosure of the actual substance name; and
- a justification demonstrating that the use of the alternative chemical name meets the need to provide enough information for necessary health and safety precautions to be taken in the workplace and the need to ensure that risks from handling the mixture can be controlled.
The proposed alternative chemical name can be a name which identifies the most important functional groups of the substance or an alternative designation.
Tip: When deriving the alternative name, it is recommended to use the "Lexicon guide" (Annex VI, Part B of the Dangerous Preparations Directive).
For further details on how to prepare the dossier, please see Manual: How to prepare a request for use of an alternative chemical name for a substance in mixture.
3. Submit the IUCLID file and the required attachments via REACH-IT.
If you do not receive a confirmation message after submitting the request, contact the ECHA Helpdesk."
What happens next?
Upon receiving the request, ECHA will perform a format check and a ‘Business Rules' check to verify that the dossier is complete and can be processed.
If the dossier passes the ‘Business Rules' check, ECHA will send you an invoice. When ECHA has received the payment, a decision on the request for use of an alternative name will be communicated to you within six weeks.
If ECHA does not accept the request for the use of an alternative chemical name, or if it later amends or withdraws its approval on the use of the alternative chemical name, a review of the decision can be requested. The request for review should be submitted within two months from receipt of the decision, and should be submitted using a specific webform.
Please note that ECHA will always send all communication related to the request, including the decision, via the REACH-IT messaging system directly to the requester.