Alternative chemical name in mixtures
Manufacturers, importers and downstream users based in the EU who are concerned about disclosing the full composition of a mixture, on the label or in the safety data sheet, can request the use of an alternative chemical name for a substance to protect the confidential nature of their business, and in particular, their intellectual property rights.
Important: Please note that 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)
Requests according to CLP
Any requests for the use of an alternative chemical name approved by ECHA will be valid in all EU member states. When approved, the alternative chemical name can be used on the label and in the safety data sheet of the mixture(s) instead of the substance name.
An alternative chemical name can only be approved in these cases:
- When the substance does not have a Community workplace exposure limit.
- The use of the alternative name meets the need to provide enough information to take necessary health and safety precautions at the workplace and that the risks from handling the mixture can be controlled.
- The substance is classified only in certain hazard classes (see 1.4.1 (III), Annex I, CLP Regulation).
Requests for use of an alternative chemical name according to CLP are subject to a fee. In general, the fee depends on the company size and number of mixtures in a request.
Legal reference: CLP, Article 24 and Annex I, 1.4.1
Decisions taken under the Dangerous Preparations Directive
If an alternative name was approved by a Competent Authority before 1 June 2015, it can be used in the mixtures specified in the approval also after 1 June 2015, provided that the substance for which the name was approved fulfils the criteria in Article 24 and Annex I, 1.4.1 to the CLP Regulation.