Questions and Answers

CLP

Public C&L Inventory

[628] What is the Classification & Labelling Inventory?
CLP
Public C&L Inventory
Version: 1.1
Latest update: 04/06/2015

The Classification & Labelling (C&L) Inventory is a database which contains classification and labelling information on substances notified under Regulation (EC) No 1272/2008 (the CLP Regulation) and registered under Regulation (EC) No 1907/2006 (the REACH Regulation). It also contains the list of legally binding harmonised classifications (Tables 3.1 and 3.2 of Annex VI to the CLP Regulation). It is established and maintained by ECHA.

The C&L Inventory serves multiple purposes:

- It is a tool for hazard communication and a source of basic information on substances placed on the market which meet the criteria for classification as hazardous or are subject to registration, for suppliers of substances, the general public and Member State Competent Authorities (MSCAs);

- It reveals differences in the classification and labelling of the same substance applied by different suppliers, thus pointing to the need for further discussion among companies to explore the reasons for differences and/or agree on the correct classification, evaluation needs or the need for a legally binding harmonisation of a particular classification and labelling of a substance;

- It is an important tool for hazard communication and risk management, e.g. when MSCAs assess the need for potential authorisations and restrictions of hazardous substances under REACH.

[629] What is the content of the public Classification and Labelling (C&L) Inventory?
CLP
Public C&L Inventory
Version: 1.1
Latest update: 04/06/2015

Article 42 of the CLP Regulation and Article 119(1) of the REACH Regulation stipulate which elements of a notification should be publicly accessible in the Classification and Labelling Inventory.  These consist of certain elements of the substance identity and all classification and labelling (C&L) elements.   The EC name and number of all notifications for EINECS substances and, wherever possible, all other substances in the EC inventory, are published.  In addition, when a substance is classified in certain hazard classes referred to in Article 119(1)(a) of the REACH Regulation by at least one notifier then the C&L elements are published from all notifications for that substance.  The IUPAC name is only published from notifications classifying in the hazard classes referred to in Article 119(1), however.

Flags in the Public C&L Inventory also indicate whether the displayed classification and labelling is derived from a joint submission in the REACH registration process and in the future agreed entries between the notifiers according to Article 41 to CLP will be flagged.

The information published in the C&L Inventory is not reviewed or verified by ECHA or any other authority and can be changed without prior notice. ECHA does not guarantee the correctness of the information published in the database as it is automatically disseminated from the notifications and registration dossiers.

[630] What is NOT in the Public C&L Inventory?
CLP
Public C&L Inventory
Version: 1.0
Latest update: 04/06/2015

The Public C&L Inventory does not contain contact details of notifiers or registrants, as this is not foreseen in the CLP Regulation. In order not to disclose confidential business information, no detailed information on impurities or additives is included in the Public C&L Inventory either. In addition, notifiers and registrants have the possibility to claim the IUPAC name confidential (further information on how to flag the IUPAC name confidential can be found in Data Submission Manual Part 12). If so, it will not be included in the Public C&L Inventory.

Furthermore, IUPAC names of substances from notifications which do not classify in one or more of the hazard classes stipulated in Article 119(1)(a) of REACH, are not included.  If no substance identifier (EC name or number, IUPAC name, CAS no etc.) can be published, the notification cannot be displayed in the public inventory.

[631] How can I search information in the Public C&L Inventory?
CLP
Public C&L Inventory
Version: 1.0
Latest update: 04/06/2015

The Public C&L Inventory provides for multiple search options based on both substance identity and classifications. If one is interested in a particular substance or group of substances it can be searched using the full or partial EC name, the name as contained in Annex VI of the CLP Regulation, the IUPAC name or the full or partial EC, CAS or Annex VI Index numbers.

For ease of use, the classifications have been separated into physical, health and environmental hazard classifications and the user can choose either the abbreviated hazard class and category codes (e.g. Acute Tox. 4) or the hazard statement code (e.g. H302).  Combining the substance identity and classification elements will further refine the search results.

The search results are provided based on substances. By selecting one substance from the results, the user is guided to a summary page listing first the harmonised entries (if any) and then the aggregated classifications from the notifications. A further selection of a particular aggregation will provide the detailed view of the aggregated notification.

ECHA has noticed that in individual cases a wrong substance name has been supplied by notifiers with their notification. As ECHA displays the information as provided in the notifications, without verification of the accurateness of the data, this may result in spurious results when searching by substance name, as a seemingly unrelated substance could be displayed in the results. In such cases, it is advised to use the second page view where all published IUPAC names are listed, to identify whether the initially displayed name was incorrect. The grouping of substances is based on numerical identifiers and is not affected by inaccuracies in the substance name.

[632] Are notifications for the same substance grouped? If so, what aggregation rules are applied?
CLP
Public C&L Inventory
Version: 1.0
Latest update: 04/06/2015

The notifications for each substance are grouped together based on numerical identifiers such as EC or CAS numbers, where they exist. For display purposes, identical classifications are aggregated and are displayed as one entry. The number of notifications behind each aggregated classification is also indicated. The aggregation is done automatically based on both classification and labelling elements. Different states/physical forms and different reasons for no classification have not been considered during aggregation. Those differences, if any, are reflected in the detailed view of the classification entry.
[633] I have notified a substance but cannot find it in the Public C&L Inventory. What could be the reason for this?
CLP
Public C&L Inventory
Version: 1.0
Latest update: 04/06/2015

If you have just recently submitted your notification it will be included with the next data refresh of the Public C&L Inventory. A time-stamp on the search page indicates when the last refresh was made. Furthermore, ECHA only publishes those substances that are either in the EC inventory or have been notified as hazardous (according to Article 119(1) of REACH) by at least one notifier. Should your substance not be included in the above, ECHA cannot display a suitable substance identifier and the notification is not displayed.
[634] Can you confirm that details such as molecular formula, structural formula, and molecular weight will not be visible to the public when the substances are notified to the C&L Inventory?
CLP
Public C&L Inventory
Version: 1.0
Latest update: 04/06/2015

ECHA does not publish information submitted with C&L notifications which is not referred to in Article 119(1) of the REACH Regulation.
[635] Can I use the list number of the substance to search in the Public C&L Inventory?
CLP
Public C&L Inventory
Version: 1.0
Latest update: 04/06/2015

No, you cannot. During pre-registration ECHA has automatically assigned list numbers to substances not yet listed in the European Inventory of Existing Commercial Chemical Substances (EINECS), the European List of New Chemical Substances (ELINCS) and the No-Longer Polymers (NLP) list. These automatically assigned list numbers during (pre-) registration have no formal status and thus will not be published in the C&L Inventory. The only numerical substance identifiers that can be used to perform a search are official EC and CAS numbers and the Annex VI Index number (for substances with a harmonised classification and labelling).
[636] Can the C&L notification number be used to identify a substance when searching the Public C&L Inventory?
CLP
Public C&L Inventory
Version: 1.0
Latest update: 04/06/2015

No, a substance can only be identified by searching either with the CAS number, the official EC number, for substances with a harmonised classification and labelling the Annex VI Index number, or the substance name, while the C&L notification number can only be used by the notifier via REACH-IT.
[637] Why are there differing classifications for the same substance?
CLP
Public C&L Inventory
Version: 1.0
Latest update: 04/06/2015

One main aim of the inventory is to promote uniform classification of substances. However, it is to be expected that, initially, for many substances different classifications will have been notified. Some of these can be explained by technical errors made during the notification process (e.g. not assigning all labelling elements correctly) or slight differences in seemingly identical notifications (e.g. affected organs or route of exposure differs). However, notifiers can also disagree on the classification of a substance based on different interpretation of scientific studies or different access to those studies. In any case, notifiers have the legal obligation to make every effort to come to an agreed entry to be included in the inventory and inform ECHA accordingly (see Article 41 of the CLP Regulation).

There can also be different legitimate reasons why notifications for the same substance have different classifications. Different compositions or impurity profiles often lead to different classifications and the physical state and form of a substance is often very important when the hazards of a substance are assessed. The Public C&L Inventory displays the notified state and form but does not contain any information on composition or impurities.

[638] Can I rely on the classification and labelling information published in the public C&L Inventory? For example, if the classification and labelling for one substance from various suppliers differ would the C&L Inventory inform me with the 'correct' classification for my substance?
CLP
Public C&L Inventory
Version: 1.0
Latest update: 04/06/2015

The public C&L Inventory displays the notified classifications as they are reported to ECHA. No verification of the content is performed by the Agency. The notifications should therefore reflect the situation on the market. While notifiers have an obligation to undertake all efforts to come to an agreement on the classification for their substance, many may legitimately differ based on e.g. impurities or composition. This may not be immediately apparent in the public C&L Inventory. We encourage all users to discuss their concerns with their suppliers should they have any but there will be no single "correct" classification identified and highlighted by ECHA. However, the public C&L Inventory will indicate where a legally binding harmonised classification is included in Annex VI of the CLP Regulation and where the classification of a substance is the result of a joint registration under REACH.
[639] How can companies get in touch with each other and when will they be able to do so? Would notifiers be put in touch with others if there is a disagreement over the classification?
CLP
Public C&L Inventory
Version: 1.1
Latest update: 04/06/2015

In accordance with Article 41 of the CLP Regulation it is the responsibility of the registrant(s) and notifier(s) of the same substance to make every effort to come to an agreed entry included in the Public C&L Inventory. However, ECHA has received millions of notifications for more than 100,000 substances for the C&L Inventory. Thus, the process of agreement for such a large number of notifiers and substances will be long and requires the active involvement of all parties concerned.

In order to aid this process, ECHA has launched the C&L platform to allow notifying companies to get in contact with each other, so that they can start discussing different classification and labelling entries for the same substance. The C&L Platform is accessible through the “Discuss” button on each substance summary page.  For more information please see http://echa.europa.eu/web/guest/information-on-chemicals/cl-inventory/cl-platform

[640] It is not possible to make a C&L notification redundant. Does this mean that if a company makes a notification for a substance and then stops supply their C&L notification for that substance will still be on the C&L inventory many years after they have stopped supply and may no longer be accurate?
CLP
Public C&L Inventory
Version: 1.0
Latest update: 04/06/2015

Cease of manufacture or import does not automatically mean that a substance is no longer on the market. However, ECHA is currently investigating the possibilities of being able to indicate the submission date or when the notification has been updated for the last time in the public C&L Inventory. This information may allow concluding on the actuality of the classification and labelling information for the substance displayed in the Inventory.
[641] Is the harmonised list according to DSD criteria (Table 3.2 of Annex VI to CLP) in the Public C&L Inventory?
CLP
Public C&L Inventory
Version: 1.1
Latest update: 04/06/2015

The classification and labelling of harmonised substances according to the DSD criteria (Table 3.2 to Annex VI of CLP) is included in the C&L Inventory.  The DSD classification of each harmonised substance can be found directly underneath the CLP classification.  We have also included the categorisation of harmonised substances according to the Seveso II Directive.

[642] Why are the precautionary statements not published?
CLP
Public C&L Inventory
Version: 1.0
Latest update: 04/06/2015

Pursuant to Article 40(1)(f) of the CLP Regulation, a notification to the C&L Inventory should include the applicable CLP hazard pictograms, signal words and hazard statements as well as any supplemental hazard statements set out in sections 1.1 and 1.2 of Annex II of CLP or provided in Part 3 of Annex VI to CLP. ECHA does not consider precautionary statements as part of the classification and labelling within the meaning of Article 119(1) of the REACH Regulation. In addition, the provision of precautionary statements is not compulsory in C&L notifications. Furthermore, the precautionary statements are not listed in the tables with harmonised classification and labelling.
[643] Some aggregated notifications have no classification elements visible while others are labelled "not classified". What is the difference between these?
CLP
Public C&L Inventory
Version: 1.1
Latest update: 04/06/2015

When notifiers wish to notify a substance for which they believe no classification is required, they can tick the appropriate tick-box (labelled "not classified"). In this case, no further details on the classification and labelling of the substance are needed. The C&L Inventory displays these notifications with the label "not classified" and the third page view is disabled. Some notifiers have submitted notifications with no C&L elements but which the tick-box "not classified" was not ticked. For these notifications, ECHA cannot verify whether their intention was to submit no classification or whether the notifier simply forgot to add the C&L elements. These notifications are therefore displayed separately.

[644] Will I have the possibility to download my search results from the C&L Inventory?
CLP
Public C&L Inventory
Version: 1.1
Latest update: 04/06/2015

Yes, there is a possibility to download and export the search results in excel or csv format.  No classification and labelling information can be downloaded.

[645] How can I use my search results from the C&L Inventory?
CLP
Public C&L Inventory
Version: 1.0
Latest update: 04/06/2015

Reproduction or further distribution of search results may be subject to copyright protection. Please note that using this information without obtaining the permission from the owners of the respective information might violate the rights of the owner. ECHA is not responsible for any copyright or other infringements that may be caused by you using the information.