Questions and Answers
"CLP" or "the CLP Regulation" is Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures, amending and repealing Directives 67/548/EEC and 1999/45/EC, and amending Regulation (EC) No 1907/2006 (REACH). It implements the United Nations Globally Harmonised System of classification and labelling of chemicals (GHS) into EU law:
Regulation (EC) No 1272/2008 (CLP):
Regulation (EC) No 1907/2006 (REACH): http://www.echa.europa.eu/regulations/reach/legislation
The CLP Regulation came into force on 20 January 2009. It fully replaced the Dangerous Substances Directive 67/548/EEC (DSD) and the Dangerous Preparations Directive 1999/45/EC (DPD) from 1 June 2015.
Directive 2008/68/EC on the inland transport of dangerous goods which shall have been transposed by Member States into national law by 30 June 2009 includes neither references to CLP nor to the previous legislation on classification and labelling. CLP Article 1(6) states "Save where Article 33 applies this Regulation shall not apply to the transport of dangerous goods by air, sea, road, rail or inland waterways." Accordingly, CLP does not change the transport legislation. However, CLP lays down in Article 33 specific rules for labelling of outer packaging and single packaging which are transported.
You can find the latest consolidated version of CLP via the ECHA website at: http://echa.europa.eu/web/guest/regulations/clp/legislation. Note that the text has no legal value. For legal purposes please refer to the texts published in the Official Journal of the European Union.
The European Commission issues Adaptations to Technical Progress (ATPs) to the CLP Regulation, which provide updates to the harmonised classification and labelling in Table 3.1 of Annex VI to CLP. The updated version of this table is included in the Classification and Labelling Inventory managed by ECHA.
ECHA has prepared an unofficial excel table containing all updates to the harmonised classification and labelling in Table 3.1 of Annex VI to CLP (http://echa.europa.eu/information-on-chemicals/annex-vi-to-clp). The table may not be entirely in line with the legally-binding entries in Annex VI to CLP as published in the Official Journal of the European Union (http://echa.europa.eu/regulations/clp/legislation [PDF]).
The CLP Regulation was adapted to technical progress for the first time by Commission Regulation (EC) No 790/2009 of 10 August 2009 that entered into force on 25 September 2009. This first Adaptation to Technical Progress (ATP) requires manufacturers, importers and downstream users to apply the harmonised classifications of the substances included in the first ATP from 1 December 2010.
Yes. A manufacturer, importer or downstream user can submit a proposal to introduce additional harmonised classification and labelling elements to an entry in Part 3 of Annex VI to CLP directly to the Agency. A condition for submitting such a proposal is that the additional harmonised classification and labelling elements concern a hazard class or differentiation not yet covered by the harmonised classification of the substance in Part 3 of Annex VI. The procedure is described in Article 37(2) of CLP.
Where a change to the existing harmonised classification and labelling elements of a substance in Part 3 of Annex VI to CLP is proposed, the manufacturer, importer or downstream user must submit the proposal to a competent authority of a Member State in which the substance is placed on the market (Article 37(6)).
When a manufacturer, importer or downstream user has new information which may lead to a change of the existing harmonised classification and labelling of substances regulated under the Biocidal Products Regulation (EU) 528/2012 (the BPR) or under Regulation (EC) No 1107/2009 on plant protection products (the PPPR), they must act according to Article 37(6) CLP.
As harmonised classifications in Annex VI are binding for the endpoints covered in the entry (except the minimum classifications (section 1.2 in Annex VI to CLP) indicated by the reference * in Table 3.1), it is not possible to use a different classification and labelling from a harmonised one until an ATP amending it has been published.
The C&L Platform is a web-based discussion forum, established by ECHA to assist registrants and notifiers of substances to the C&L Inventory in agreeing on entries to be included in the Inventory. Multiple different classifications have been notified for many substances and Article 41 of the CLP Regulation stipulates that “...where the notifications of classification and labelling to the C&L Inventory result in different entries for the same substance, the notifiers and registrants shall make every effort to come to an agreed entry to be included in the inventory…” The Platform is an easy solution for notifiers and registrants to contact each other and discuss the appropriate classification and labelling of their substances.
The C&L Platform can only be accessed through the C&L Inventory and is only accessible to registrants and notifiers of substances to the C&L Inventory. When two or more different classifications have been notified for the same substance, a discuss button becomes available in the summary page for that substance in the C&L Inventory. Upon clicking this button, the users are guided to a login page where they enter the platform discussion room for that substance using their REACH-IT account login details. Only those registrants and notifiers who have submitted a notification for this substance through REACH-IT can access the relevant discussion room. Discussion rooms for other substances are not available and they need to be accessed through their relevant C&L Inventory summary pages.
When an agreement on the appropriate classification has been reached, the notifiers must update their notifications accordingly through REACH-IT. When updating the notification, the notifiers should indicate that the update is as a result of an agreement reached through the C&L Platform by ticking the appropriate tick-box. All notification tools are compatible with one another when updating. The updated notification will be included in the C&L Inventory upon the next data refresh. When you update a notification by submitting a IUCLID file (e.g. by updating a registration dossier), please indicate that the update is due to a change in the classification and labelling by ticking the appropriate tick box and mention agreement in the C&L Platform in the free-text field alongside it.
You will not have to reveal your identity to other participants. When you access a discussion room for the first time you can choose whether to post using an automatically generated alias or your real identity. The real identity is the name and surname provided in your REACH-IT user account details. Should you choose to post using an alias, you are presented with the option of continuing to post under the same alias or to use your real identity whenever you access the discussion room. Once you post using your real identity, you cannot revert back to using an alias and all your previous posts will be associated with your real identity. The moderators of the platform (members of ECHA staff) will have access to your real identity. When accessing other discussion rooms, you are presented with the option of using an existing alias, your real identity or a new alias. The identity chosen in each discussion room is independent of other rooms.
ECHA hosts the C&L Platform and manages its functions, ensuring interlinks with the C&L Inventory and REACH-IT. Members of ECHA staff act as moderators, responding to reports of abuse by users and providing technical assistance to users. ECHA does not participate in and/or actively monitor on-going discussions in the C&L Platform.
No, the bridging principle "Review of classification where the composition of a mixture has changed" can only be used for mixtures containing the same constituents (ingredients). It is only the concentrations of the hazardous constituents (ingredients) and not the constituents themselves that are permitted to change, within the ranges specified in Table 1.2 in Part 1 of Annex I which applies Article 15(2)(a).
No, not necessarily. For a range of hazards, the classification criteria have changed, e.g. for many physical hazards where the test methods which determine the classification criteria are often different from those of DSD. For other hazards, the applicable concentration limits for taking into account the classification of its constituents, additives and impurities contained in the substance have changed, e.g. for the irritation and corrosive hazards. This means that in cases where there is no reliable test information on the substance as a whole and the bridging principles cannot be applied, use of the calculation rules using concentration limits may lead to a classification under CLP, even though the same substance was not classified under DSD.
No, this is not necessary. A supplier will only have to classify the substance in the form that is going to be placed on the market and in which it can reasonably be expected to be used.As the particle size may have a significant effect on the test result, it should be explicitly specified in the test report for the relevant hazard what the particle size is. This does not mean that several classifications have to be performed in order to cover different particle sizes of the same substance. It means that the classification based on the particle size that is placed on the market has to be provided. In cases where several particle sizes are placed on the market or where the particle size may be altered during transport or storage, a worst-case approach should be used. This would normally imply using the classification based on testing the smallest particle size that could occur.
If particle size is relevant for classification and safe handling and use, this should be mentioned in the Safety Data Sheet. Information on deviating classifications due to different particle sizes should be mentioned in the Safety Data Sheet as well.
Under CLP, the classification criteria for the aspiration hazard require the determination of the kinematic viscosity while the viscosity based on flow time is not part of the classification criteria. ISO 2431 contains correlations between flow time and kinematic viscosity. However, there is no general correlation describing the temperature dependence of the viscosity, and expert judgement is necessary.
Yes, you do. As stated in section 188.8.131.52 of Annex VI to the CLP Regulation, impurities are not normally mentioned in Annex VI to CLP entries unless they contribute significantly to the classification of the substance. This means that the entry in Annex VI to CLP relates normally to the toxicity of the "pure" substance and impurities have not been taken into account. Therefore, if the substance placed on the market contains an impurity not specified in the corresponding entry in Annex VI to CLP, the presence of classified impurities shall be taken into account for classification purposes in accordance with Article 11(1) CLP.
The Commission Regulation (EC) No 286/2011 (second ATP to CLP) entered into force on 19 April 2011. In accordance with Article 3 of this ATP, Note H no longer applies to entries marked with the Note from 1 December 2012.
A new or revised harmonised C&L of a substance set out in Annex VI to CLP must be applied from the date specified in the respective ATP, although suppliers may use this classification before that date.
In cases where a supplier decides not to apply the harmonised C&L of a substance before this date, the question arises whether they should nevertheless take into consideration the opinion adopted by the ECHA Risk Assessment Committee (RAC) on the harmonised C&L for that substance in the self-classification of a substance or mixture.
When suppliers consider the self-classification of their substance or mixture before placing them on the market (Article 4(1) of CLP), they must identify and examine all available information (Article 5 of CLP). The classification must reflect the latest scientific knowledge (Articles 5(1)(d) and 15 of CLP). During the transitional period for compliance with a new harmonised C&L for a substance, the RAC opinion for that substance should be considered as the latest reliable scientific evidence that should be reflected in the self-classification of the substance or mixture, unless the supplier has other scientific evidence that differs from the RAC opinion and leads to a different conclusion.
If the C&L of a substance is already harmonised in the same hazard class, compliance with the existing harmonised C&L is legally required until it is formally changed in an ATP to CLP. The new harmonised C&L may be voluntarily applied as soon as the respective ATP enters into force. At the date of applicability, as provided for in the respective ATP, the suppliers are obliged to comply with the new C&L.
Yes, the classification and labelling (C&L) of biocidal products needs to be updated in line with the change in harmonised classification within the timelines specified below. If the C&L of a substance in the product is already harmonised, compliance with the existing harmonised C&L is legally required. The new harmonised C&L may be voluntarily applied as soon as the respective ATP enters into force. At the date of applicability as provided for in the respective ATP, the suppliers are obliged to comply with the new C&L.
Further to this, Article 30(3) of CLP states that the label of a biocidal product should be updated in line with the requirements of the biocidal products legislation. The Commission Implementing Regulation (EU) No 354/2013 on changes of biocidal products gives the authorisation holder 12 months after implementation of the change to notify the updated hazard and precautionary statements to all the Member States in which the product is authorised or, where relevant, ECHA (see Annex, Title 1, Section 2).
It is assumed that pH has been taken into account when setting an SCL for a substance for skin corrosion/skin irritation or eye damage/eye irritation.
When a mixture only contains one corrosive or irritant ingredient (acid or base) with an SCL, the mixture should be classified according to this SCL even if the pH of the mixture is extreme. However, the SCL reflects a situation where the mixture does not contain any other ingredient that might affect the classification for that endpoint. If other ingredients in the mixture affect the irritant/corrosive properties, this has to be taken into account.
If a mixture contains any other substances than the one with an SCL, which may affect the corrosive or irritant properties of the mixture, the SCL may not determine the classification of the mixture. Such ingredients can be surfactants, other acids or bases, which either themselves possess corrosive or irritant properties or may be expected to affect the corrosive or irritant properties of the substance with the SCL, for example, by increasing the permeability of the skin. In that case, the classification should be based on the pH value of the mixture, unless consideration of the acid/alkali reserve suggests that the mixture may not be corrosive, and data from in vitro tests confirm that classification as corrosive is not justified. Classification based on the pH value of the mixture may lead to a more severe classification than if based on the SCL. A more severe classification may also result when either the additivity rule (Tables 3.2.3 or 3.3.3 of Annex I to CLP) or non-additivity rule (Tables 3.2.4 or 3.3.4 of Annex I to CLP) applies.
Where the aspiration toxicity of a mixture is based on its components, two conditions need to be met.
Firstly, a mixture must contain a total of 10 % or more of a substance or substances classified in Aspiration Toxicity Category 1.
Secondly, the kinematic viscosity of the mixture must be at or below 20.5 mm2/s, measured at 40°C (point 184.108.40.206.1.1 of Annex I to CLP).
When these conditions are both met, the mixture must be classified in Aspiration Toxicity Category 1.
Suppliers had to introduce CLP classifications into the safety data sheet (SDS) for substances from 1 December 2010 and for mixtures from 1 June 2015. However, mixtures already placed on the market before 1 June 2015 and classified, labelled and packaged according to the Dangerous Products Directive (DPD) do not need to be re-labelled or re-packaged according to CLP before 1 June 2017. Their SDSs also do not need to be aligned with the CLP classification until 1 June 2017.
In conformity with Article 2 of Regulation (EU) 2015/830, without prejudice to Article 31(9) of REACH, the SDS for mixtures provided to any recipient at least once before 1 June 2015 may continue to be used and need not comply with the Annex to Regulation (EU) 2015/830 until 1 June 2017. For both substances and mixtures, Annex II to REACH was replaced by the Annex to Regulation (EU) 2015/830 from 1 June 2015.
CLP Article 48(1) outlines the information which must be provided in an advertisement for a substance classified as hazardous. The advertisement shall contain the hazard class and/or the applicable hazard categories, as appropriate, e.g. acute oral toxicity category 3.
CLP requires that where a member of the general public can purchase a mixture without first seeing the label, and where that mixture is classified as hazardous or contains a hazardous substance as referred to in CLP Article 25(6), then the advertisement for that mixture must mention the type or types of hazard as indicated on the label.
The type of hazard is best specified by providing the relevant hazard statements, including the supplemental hazard statements as referred to in CLP Article 25(6). It is also recommended that the hazard pictograms and signal word are mentioned, where appropriate, to alert the reader to a potential hazard.
No, section 2.2 of an SDS is intended only for supply (CLP) pictograms, which are described in Annex V to the CLP Regulation. The transport labels can be included in section 14 of the SDS (see also Annex II to REACH).
Re-fillers are downstream users of substances or mixtures whose use is limited to transferring substances or mixtures supplied to them from one container (or packaging) into another. Re-fillers are therefore not obliged to classify in accordance with Title II of CLP, but may also take over the classification derived in accordance with Title II already by another actor in the supply chain provided the re-filler does not change the composition of the substance or mixture that is being refilled. In any case the re-filler has to ensure that the labelling and packaging is in accordance with CLP. This can mean that the original label must be replaced by another one. For example, when the contents of a 200 l drum is decanted into 25 ml bottles, the new label should be in line with the small packaging exemptions, unlike the original bigger one which required full labelling.
Note that re-fillers established within the EU who are supplied with substances or mixtures by an actor outside the EU are considered to be importers under CLP, unless they can benefit from the provisions foreseen for re-importers, see FAQ ID=168. This means that they have the obligation to classify these substances and mixtures and to notify relevant substance information to the Classification and Labelling (C&L) Inventory.
Under CLP, recovered substances and mixtures will normally have to be treated in the same way as other substances and mixtures under CLP. This means that they have to be classified according to Title II of CLP and the substances have to be notified to the C&L Inventory, unless the establishment undertaking the recovery (manufacturer of the recovered substance) has already submitted a registration under REACH and included the information necessary for a notification. In case the establishment undertaking the recovery can rely on the exemption from the REACH registration provisions for recovered substances pursuant to REACH Article 2(7)(d), it would still have to notify the recovered substances to the C&L Inventory, in accordance with CLP Article 39(b) and 40.
When classifying under the CLP Regulation, the establishment undertaking the recovery may take over the classification derived in accordance with Title II of CLP already by the registrant of the same substance, if this is appropriate. When notifying in such cases to ECHA, it is recommended to retrieve the classification and labelling information provided earlier by the registrant of the original substance from ECHA's Classification & Labelling Inventory and agree to it.
The number of hazard statements on the label is in principle not limited as they will normally have to reflect all hazard classifications of a substance or mixture. The only exception is for evident duplication or redundancy.
In the EU, only those labels which comply with the CLP rules will be accepted. This means that those provisions that are laid down in Title III of the CLP Regulation and the details regulated in its Annexes I – V must be respected. However, many aspects in relation to the arrangement of labelling elements and in relation to supplemental labelling information are at the discretion of the supplier of the hazardous substance or mixture.
No, it isn't. CLP Articles 21 and 22 require that the statements as such are put on the label, in accordance with the wording provided in Annex III and Annex IV, Part 2. The codes corresponding to these statements are not required for the label, but are not explicitly excluded. It is up to the supplier to decide whether he will include the codes on the label as well.
Yes, they do. Active substances, plant protection products within the scope of Regulation (EC) No 1107/2009 or biocidal products within the scope of Regulation (EU) 528/2012, which are classified as hazardous, must bear a CLP label including the relevant hazard statements, precautionary statements, signal word and pictograms.
In addition, the label of a hazardous plant protection product must also display the statement EUH401 ("To avoid risks to human health and the environment, comply with the instructions for use"). However, in relation to any other aspects of labelling, the provisions of the respective regulations apply, e.g. for the update of a label of a plant protection or biocidal product, see CLP Articles 15(5) and 30(3). Further information can be found in the Guidance on labelling and packaging in accordance with the CLP Regulation available on the ECHA website at http://echa.europa.eu/guidance-documents/guidance-mainly-for-industry-use
Note that an active substance can also be placed on the market for non-pesticidal or non-biocidal uses. In these cases, the labelling provisions set out in CLP Title III apply in full. This means, for example, that the update of the relevant label has to follow the provisions of CLP Article 30(1) and (2).
CLP Article 25 introduces the concept of "supplemental information", which is intended to incorporate additional labelling information 'over and above' that listed in CLP Article 17 (1) (a) to (g). Any non-EU hazard information included along with the CLP label elements may be considered as supplemental information and placed alongside the CLP labelling elements so long as it does not contradict or cast doubt on the validity of the information required by CLP Article 17 (1) (a) to (g), nor makes it more difficult to identify such information. This can only be determined on a 'case by case' basis depending on the information being proposed by the importer. Additional guidance on supplemental labelling information can be found in Section 4.8- 'Supplemental labelling information' of the CLP labelling and packaging guidance available on the ECHA website at http://www.echa.europa.eu/guidance-documents/guidance-on-clp
The general rules for the application of labels are outlined in CLP Article 31. For the hazard pictograms, as detailed in CLP Article 31 (4), the provisions of Annex I, Section 1.2.1, to CLP and Annex V to CLP shall apply. According to Annex V to CLP, hazard pictograms shall have a black symbol on a white background with a red frame wide enough to be clearly visible. Hazard pictograms shall be in the shape of a square set at a point. Each hazard pictogram shall cover at least one fifteenth of the minimum surface area of the label dedicated to the information required by CLP Article 17 (as defined in Table 1.3 in Section 220.127.116.11 of Annex I, 2nd ATP to CLP). Where a supplier chooses to use a label that is larger than the minimum dimensions for a certain capacity of the package, it is not necessary for the size of the pictogram also to be increased, provided it covers one fifteenth of the relevant minimum dimensions and remains proportional to the size of the packaging. The minimum area of each hazard pictogram shall not be less than 1 cm². Note that the size of the pictogram relates to the dimensions of the pictogram itself, and not to the size of the virtual square where the pictogram is embedded. Further guidance can be found in Section 5.2- 'Size of the label and of the label elements' of the Guidance on labelling and packaging in accordance with the CLP Regulation available on ECHA's website at: http://www.echa.europa.eu/guidance-documents/guidance-on-clp
The CLP Regulation does not require the labelling of substances or mixtures that are only exported and that, within the EU, are only subject to transport operations. It is necessary to take worker health and safety considerations into account during the production packaging and storage stages, to ensure that these substances and mixtures are handled safely.
However, the PIC Regulation ((EU) 649/2012) concerning the export and import of hazardous chemicals (which implements the Rotterdam Convention within the EU) requires that all exported chemicals are classified, labelled and packaged in accordance with the CLP Regulation, the Plant Protection Products Regulation ((EC) No 1107/20), the Biocidal Products Regulation ((EU) No 528/2012) or any other relevant EU legislation, unless those provisions would conflict with any specific requirements of the receiving countries. Further information can be found in sections 4.1 and 6.10 of the Guidance for implementation of the PIC Regulation.
The labelling and packaging requirements for hazardous transported goods are laid down in the respective transport legislation, based on the UN Model Regulations.
According to the criteria given in section 1.2.1 of Annex II to CLP, the hazard statement applies to 'substances and mixtures which in contact with water or damp air, evolve gases classified for acute toxicity in category 1, 2 or 3 in potentially dangerous amounts, such as aluminium phosphide, phosphorous pentasulphide.' No further criteria or guidance are provided as to when this hazard statement should be assigned and no appropriate test methods are indicated. It is recommended that any amount of acute toxic category 1, 2 or 3 gas emitted triggers the inclusion of EUH029. It is thus also recommended to add this sentence to each substance or mixture that releases a toxic gas when in contact with water.
No. Substances or mixtures under the scope of the CLP Regulation can not be exempted from the classification, labelling and packaging requirements regardless of how low the risk is estimated to be and regardless of the size of the packaging. However, certain derogations apply for labelling of small packagings according to Article 29 of CLP.
Article 18(3) of CLP provides that the identity of all substances in a mixture that contribute to the classification of the mixture in certain hazard classes must be given on the label. A maximum of four chemical names are to be included, unless more are needed to reflect the nature and severity of the hazards.
There are no strict rules on how to decide which substances should take precedence to be named on the label, but the following may help in the selection.
For non-additive health hazards (e.g. germ cell mutagenicity, carcinogenicity, reproductive toxicity, respiratory or skin sensitisation and specific target organ toxicity categories 1 and 2), all ingredients which are present in the mixture above the generic or specific concentration limit should be considered as ”primarily responsible for the major health hazards” within the meaning of Article 18(3)(b) CLP and included on the label.
For the additive health hazards mentioned in Article 18 (3)(b) CLP (e.g. acute toxicity, skin corrosion, serious eye damage, specific target organ toxicity category 3 and aspiration hazard), all ingredients which are present in the mixture above the generic or specific concentration limits should be included on the label. However, where there are several ingredients contributing to classification for one hazard endpoint, only the ingredients primarily contributing to the classification, for example, those closest to the GCL or SCL, need to be included on the label, and thus the names of other ingredients with limited contribution to the classification are not required.
In addition, specific labelling rules apply to mixtures containing skin and respiratory sensitisers. See Annex I Table 3.4.3 and Annex II, point 2.8.
No, they are not. Article 33(1) of CLP outlines that when a package consists of an outer and an inner packaging, together with an intermediate packaging, and the outer packaging meets the labelling provisions in accordance with the rules on the transport of dangerous goods, the hazard pictograms required by CLP do not need to appear on the outer packaging.
For the purpose of CLP, transport labelling is considered to include the limited/excepted quantity marks (chapters 3.4 and 3.5 of the UN Model Regulations for the transport of dangerous goods). This is explained in the Guidance on labelling and packaging (chapter 5.4) that states that labelling in accordance with CLP is required only when neither:
- 'normal' transport labelling elements, nor
- other transport labelling elements such as ‘limited/excepted quantity marks' are needed on the outer packaging.
This means that limited/excepted quantities are considered as transport labelling and therefore CLP pictograms are not required when those limited/excepted quantity marks are carried on the outer packaging. CLP labelling may however be used, if desired according to Article 33(1) of CLP.
The precautionary statement P501 with appropriate specification of where to dispose of the content/container (e.g. public waste disposal or recycling facility), in accordance with the applicable regulation, must be included on the label of any substance or mixture supplied to the general public if the substance or mixture is classified in the hazard classes and categories listed under P501 in Table 6.5 of Annex IV to the CLP Regulation.
- Substances which are subject to registration under REACH (= 1 tonne/year) and placed on the market. This includes substances on their own, substances contained in mixtures and certain substances contained in articles where REACH Article 7 provides for their registration. Notification of these substances is not necessary where a manufacturer, importer or Only Representative (OR) has already registered the substance with the classification and labelling according to CLP when its notification in line with CLP Article 40(1) is due. In particular, notification is not required of the importers covered by a registration that has already been done by an OR on their behalf. However, importers will have to notify a substance within one month of its placing on the market where the OR has not yet submitted the registration.
- Substances classified as hazardous under CLP and placed on the market irrespective of tonnage. This includes substances which are classified as hazardous under CLP, but which are exempted from registration, e.g. polymers referred to in REACH Article 6(3); and
- Substances classified as hazardous under CLP and present in a mixture above the concentration limits specified in Annex I of CLP or as specified in Directive 1999/45/EC, where relevant, which results in the classification of the mixture as hazardous, and where the mixture is placed on the market.
No, according to Article 39(b) of the CLP Regulation, the requirement for notification to the Inventory includes all hazardous substances within the scope of CLP, either on their own or contained in a mixture above legally defined concentration limits, and which are imported or manufactured and placed on the market within the EU. In other words: the requirement for notification goes beyond substances manufactured or imported in quantities of 1 tonne or more per year.
Yes, it is. Article 39(a) of CLP states that "substances subject to registration in accordance with Regulation (EC) No 1907/2006" fall within the scope of the C&L Inventory when they are placed on the market. Therefore, this applies to substances subject to registration under REACH and placed on the market, regardless of whether they are hazardous or not. Where a substance is not classified, the "not classified" option should be selected in Bulk XML file or in IUCLID 5 dossier, or in REACH-IT C&L on-line wizard when notifying it to the Inventory.
However, if the substance is not subject to registration and does not meet the criteria for classification as hazardous there is no notification obligation. It is noted that where a substance has not yet been registered, the notifier should notify according to the provision of CLP Article 40(3) since notification is independent from the registration deadlines (see also FAQ ID=209). Note also that if a company has already submitted a registration dossier for the substance including the classification and labelling according to CLP, the same company does not have to submit a separate notification to the C&L Inventory.
Yes, you do. CLP Article 39(b) refers to all hazards. This includes notification of a substance classified for a particular physical hazard and contained in a mixture whenever the mixture is placed on the market and needs to be classified for a physical hazard due to the presence of that substance. It should be noted that the physical hazard class to which the mixture belongs could be different from that of the substance(s) causing the hazard. Expert judgment should be sought in case of doubt.
If a mixture that is classified as dangerous (according to DPD - until 01/06/2015) or as hazardous (according to CLP) is imported, CLP Article 39(b) requires that the substances in the mixture which led to this classification be notified to the C&L Inventory. According to CLP Article 40(1), the notified classifications of substances must be the CLP classifications. It may happen that importers are only provided with the DSD classifications of the substances contained in the mixtures, e.g. by means of a Safety Data Sheet, while further data on the substances are not available to them. At the same time the mixture has to be classified as dangerous according to the DPD criteria, due to the presence of these substances. In these situations importers should use the translation table in Annex VII to the CLP and notify the relevant CLP classifications of the substances in the mixture. Further explanation on the use of the Annex VII translation tables is provided in chapter 1.7.- 'THE APPLICATION OF ANNEX VII' of the Guidance on the application of the CLP criteria as published on the ECHA website under http://www.echa.europa.eu/guidance-documents/guidance-on-clp
No, it is not. The term "group" is not defined under the CLP Regulation, in particular it does not equate to a Substance Information Exchange Forum as defined under REACH. Nevertheless, SIEF members can decide to notify to the C&L Inventory as a group. In this case the identity of each member should be specified in the notification.
Both manufacturers who place a hazardous substance on the market and importers of a hazardous substance will have to notify the classification and labelling of the substance to ECHA. This applies to substances on their own or contained in a hazardous mixture above a relevant concentration limit, which results in the classification of the mixture as hazardous, and irrespective of the quantity placed on the market. The obligation to notify will also apply to manufacturers and importers placing on the market a substance that is subject to registration under REACH, regardless of the classification. A separate notification is not required where the same information (i.e. the classification in accordance with the CLP criteria) has already been submitted as part of a registration under REACH by the same manufacturer or importer. If the registration dossier does not contain that information, it needs to be updated with the CLP information without undue delay. Notification can also be done by a group of manufacturers or importers.
The CLP Regulation does not foresee a formal role for an OR. However, Only Representatives (OR) appointed under REACH may submit the information needed for notification to the Inventory as part of a REACH registration dossier. They may also submit separate notifications to the Inventory where they are notifying on behalf of a group of importers. Such a group notification should be done using REACH-IT. Contrary to the role of an OR under REACH, where such a solution is sought the importers will still remain responsible for the information notified to the Inventory. The submitting entity must be able to document that it has been mandated to act on behalf and in the name of the manufacturer(s)/importer(s) that are part of the group and that the manufacturer(s)/importer(s) acknowledge that they remain solely and fully responsible to fulfil all their obligations associated with the notification.
Yes, it will. Any hazardous or non-hazardous substance subject to registration and placed on the market on or after 1 December 2010 has to be notified to the C&L Inventory, unless it has been registered or notified earlier by the same manufacturer or importer. It should be noted that the duty to notify to the C&L Inventory applies to substances subject to registration under REACH irrespective of their registration deadline.
Yes, it is. Notification is independent from the REACH registration deadlines. A substance, either on its own or contained in a mixture, must be notified to the C&L Inventory within one month of the first time the company is placing it on the market. Notification can be done using any of the notification tools available at: http://echa.europa.eu/web/guest/support/dossier-submission-tools/reach-it/notification-to-the-cl-inventory
The following substance identity information is not required for the purposes of notifying to the C&L inventory: spectra, HPLC (high-pressure liquid chromatography) data, gas chromatograms nor a description of the analytical methods used for the identification of the substance and its possible impurities and additives. This is in contrast to the registration requirements under REACH where this information is required.
Yes, this is possible. A company may appear in more than one group of notifiers provided the substances being notified are different.
No, he does not. The submission of a notification to the C&L Inventory is free of charge. Similarly, there are no fees for an update of the notification.
Yes, it would. As both subsidiaries are separate legal entities, each legal entity would have to notify the substance separately if in both cases it meets the criteria for notification in accordance with Articles 39(a) or (b) and 40(1) of CLP. Alternatively, both subsidiaries (as legal entities) may prefer to notify as a group of manufacturers (see also REACH FAQ ID=29).
No, according to CLP Article 39(b), the requirement of notification to the C&L Inventory includes all hazardous substances within the scope of CLP, either on their own or contained in a hazardous mixture above defined concentration limits, and which are imported or manufactured and placed on the market within the EU. In other words, the requirement for notification applies irrespective of the tonnage manufactured or imported per year.
No, it is not. Manufacturers and importers who flag confidentiality of the IUPAC name for a substance referred to by REACH Article 119(2)(f) and (g) do not have to pay a fee when notifying it to the Classification and Labelling Inventory.
Placing a substance or mixture on the market under CLP means supplying or making the substance or mixture available to third parties, whether in return for payment or free of charge within the territory of the EU Member States and those EEA countries which have implemented the CLP Regulation.
In addition, import is deemed to be placing on the market and is defined as the physical introduction of a substance or mixture into the customs territory of the EU and those EEA countries which have implemented the CLP Regulation.
In relation to notification, placing on the market is a pre-condition. Substances which are referred to in CLP Article 39 have to be notified to the C&L Inventory if they are placed on the market. However, no notification is required if the information mentioned under CLP Article 40 has already been provided as part of a previous registration or notification by the same notifier.
The notification deadline is dependent on the date on which the substance is placed on the market. When a substance is placed on the market it must be notified to the C&L Inventory within one month.
In relation to import, the one-month timeline is counted from the day when the substance or mixture is physically introduced into the customs territory of the EU Member States and those EEA countries which have implemented the CLP Regulation.
No, a substance can only be identified by searching either with the CAS number, EC number or the substance identity. The C&L notification number can only be used by the notifier via REACH-IT.
A request to use an alternative name is made in line with the provisions under Article 24 of the CLP Regulation. This request is submitted to ECHA and any request approved by the Agency will be applicable in all EU Member States.
It should be noted that requests made and approved by Member State competent authorities under Article 15 of the Dangerous Products Directive before 1 June 2015 remain valid under CLP as indicated in Article 24(9) of CLP.
No, they are not. When a substance is present in a mixture, and the importer does not know whether it has been added as a substance as such or whether it is a constituent (additive/impurity) of a substance in the mixture, then that component must be notified if it meets the criteria in Article 39 of CLP. However, when the importer of a mixture has information that a substance present in the mixture is a constituent (additive/impurity) of another substance in the mixture, then the fields on impurities and additives can be filled in.
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.
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.
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.
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.
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.
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.
ECHA does not publish information submitted with C&L notifications which is not referred to in Article 119(1) of the REACH Regulation.
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).
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.
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.
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.
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
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.
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.
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.
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.
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.
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.
A manufacturer, importer or downstream user of a substance in a mixture may submit a request to the European Chemicals Agency, hereinafter 'the Agency', to use an alternative chemical name on the label and in the safety data sheet. Such requests under Article 24(1) should be accompanied by a fee. The level of the fees collected by the Agency, as well as the rules for payment are determined by Regulation (EU) No 440/2010 of 21 May 2010 on the fees payable to the European Chemicals Agency, are pursuant to Regulation (EC) No 1272/2008.
No, they will not.Radioactive substances and mixtures within the scope of Directive 96/29/Euratom are exempted from the scope of CLP. The reason for the exemption is that this legislation already lays down provisions for the protection of workers and the general public arising from ionising radiation, so there is no need to apply CLP in addition.
- they are placed in a free zone or free warehouse as defined under customs legislation or placed under another relevant customs procedure (transit procedure, temporary storage)
- they are kept under the supervision of the customs authorities and
- they do not undergo any form of treatment or processing.
No, they will not: As long as an intermediate falls under the definition of REACH Article 3(15)(a) concerning non-isolated intermediates, it is exempted from any obligations under CLP.It must be noted, however, that quantities of the same substance may be used in other operations or under other conditions than mentioned in this definition, which would imply that those quantities cannot be regarded as "non-isolated intermediate", but rather as a substance that may be placed on the market. Only the quantities of the substance used under the conditions qualifying it as a "non-isolated intermediate" are exempted from CLP. For the remaining quantities, the relevant requirements under CLP must be fulfilled.
Yes, substances notified under Directive 67/548/EEC (NONS) need to be classified, labelled and packaged in accordance with the CLP Regulation.
These substances are regarded as registered under the REACH Regulation. Therefore, their classification and labelling information must be included in the C&L Inventory. After a registration number has been claimed by the NONS notifier, the respective registration dossier must be updated with the CLP classifications without undue delay, and a separate notification to the Inventory is not required.
For NONS notified below one tonne under Directive 67/548/EEC and for which no tonnage band update has been done, a separate notification to the Inventory will have to be submitted if the substance is classified as hazardous and is placed on the market. So, if the annual volume of the NONS substance remains below one tonne, the company must submit a C&L notification. When the annual volume has reached or exceeds the one tonne threshold, an update in the form of a registration dossier is required.
No, it will not. Waste as defined in the Waste Framework Directive 2006/12/EC is outside the scope of CLP. Waste is any substance or object which the waste holder discards, or intends or is required to discard. This may be waste from households (e.g. newspapers or clothes, food, cans or bottles) or from professionals or industry (e.g. tyres, slag, window frames that are discarded).
As waste is not considered to be a substance, mixture or article under CLP, waste treatment operators are not considered as downstream users. At the same time waste treatment operators will not receive Safety Data Sheets on how to handle a substance or mixture during the waste phase. As long as residues from waste treatment operations are waste, i.e. they are disposed of (e.g. land-filled), they do not fall under the scope of CLP. However, residues which are recovered as substances or mixtures do fall under the scope of CLP.
Since Article 1(5)(e) of CLP only refers to food or feeding stuffs in the final state intended for the final user substances or mixtures used in food or feeding stuffs at any stage of production are not exempt from CLP and therefore must be classified, packaged, labelled and notified. For instance, the CLP Regulation applies to the manufacturer/supplier of a food additive (e.g. preservatives) who supplies the substance to another company that uses it in the production of food. In such a case, the chemical substance in the form in which it is supplied should not be regarded as a product being in the finished state intended for the final user, and the exemption stated in Art. 1(5)(e) CLP is not applicable (see also FAQ ID=179).
If you are a manufacturer or importer of an explosive substance (explosive according to the CLP criteria) that will be incorporated into an article at a later stage you do need to notify that substance. However, you do not have to notify explosive articles.
A polymer is a substance and must be notified on the basis of Article 39(b) and 40(1) of the CLP Regulation if it fulfils the criteria for classification as hazardous and it is placed on the market.
Both substances and mixtures used in scientific experimentation, analysis or chemical research are exempted from the obligations of CLP as a whole, provided they are not placed on the market and they are used under controlled conditions in accordance with Community workplace and environmental legislation. However, as soon as substances and mixtures used in scientific research & development (R&D) are physically made available or supplied to another legal entity, for example by sending samples from a university to another research institute or by importing such samples, this is considered as "placing on the market" (see CLP Article 2(18)). In this case CLP requires the supplier or importer to classify according to the available information, to label and package the sample of a hazardous substance or mixture according to CLP and to notify to the C&L Inventory the substance(s) contained therein if it/they meet(s) the criteria for classification as hazardous on the basis of available information.
Quantities of substances used in R&D are by definition smaller than 1 tonne per year and are therefore not subject to registration under the REACH Regulation. If the substance used in R&D is hazardous and placed on the EU market, it, however, needs to be notified to the C&L inventory notwithstanding its volume.
According to Article 5(1) of the CLP Regulation, manufacturers, importers and downstream users shall identify the relevant information for the purpose of determining whether the substance entails a physical, health or environmental hazard.
If neither test data are available nor any other adequate information indicates that a substance should be classified, a notification to the C&L Inventory is not required. If sufficient information is available to classify, and the substance is placed on the market, and hence when the notification to the C&L Inventory is necessary, the IUPAC name of substances used in R&D can be kept confidential as set out in the Practical Guide No 7: How to notify substances in the Classification and Labelling Inventory (see also FAQ ID=226, 227 and 228). If further information becomes available that leads to a change of the classification, the C&L notification has to be updated (see also FAQ ID=224).
Yes, it is, under the conditions of CLP Article 39(b) and 40(1): where a substance is exempted from registration under REACH, CLP requires it to be notified to the C&L Inventory if it is classified as hazardous and is placed on the market either on its own or contained in a hazardous mixture above specified concentration limits. Examples are hazardous substances that are recovered in the EU and that are exempted from registration under REACH Article 2(7)(d). On the other hand, substances which are exempted from registration under REACH and which are not classified as hazardous and placed on the market do not have to be notified to the C&L Inventory.
Yes, in principle it is, if they are placed on the market and meet the criteria for classification as hazardous. On the other hand, Annex IV only includes those substances which, according to common available information, display marginal hazardous properties only. As long as a manufacturer or importer concludes that it is inappropriate to classify a specific substance listed in Annex IV as hazardous, he does not need to notify it to the C&L Inventory.
Yes, it is, if they are placed on the market and meet the criteria for classification as hazardous. Annex V to REACH lists categories of substances as well as individual substances, e.g. certain naturally occurring substances, fatty acids and glass, which are exempted from registration under REACH as registration is deemed inappropriate or unnecessary. For certain categories, the absence of classification is a pre-condition for the exemption from registration. Other substances which are included in Annex V may have hazardous properties and therefore need to be notified according to CLP whenever they are placed on the market. However, as long as a manufacturer or importer concludes that it is inappropriate to classify a specific substance covered by Annex V, he does not need to notify information on that substance to the C&L Inventory.
Yes, they do. Active substances contained in plant protection or biocidal products have to be classified according to the CLP criteria as of 1 December 2010. In contrast to other substances supplied and used in the industrial supply chain, all hazard classifications of these substances will normally be harmonised at the EU level. The harmonised classifications appear in Tables 3.1 and 3.2 of Annex VI to CLP. However, where new information is available which may lead to a change of the harmonised classification, the procedure for harmonisation of classification and labelling of substances shall apply in accordance with Articles 36 (2) and 37 (1), (4), (5) and (6). It is also noted that the requirement for self-classification for hazard-classes and differentiations not covered by the harmonised classification as provided for in Article 4 (3) equally applies to plant protection or biocidal products.
Yes, they do. An active substance contained in a plant protection or a biocidal product counts as being registered under REACH under the conditions explained in REACH Article 15. However, where the respective dossiers do not contain the information required for notification in accordance with CLP Article 40, a separate notification to the C&L Inventory has to be made. This is because the update obligation for registration dossiers under REACH Article 22 does not apply to dossiers of active substances used in plant protection or biocidal products.
However, if the same substance has any non-biocidal or non-pesticidal use(s), a registration dossier in accordance with the provisions of REACH has to be submitted where the manufacture or import volume is equal to or above 1 tonne per year per manufacturer/importer for the total of these other uses. If the information required for a notification to the C&L Inventory has already been included in the registration dossier, a separate notification is not needed. If the registration dossier does not contain that information, it needs to be updated with the CLP information without undue delay.
No, they do not. In accordance with Article 3(5) of the REACH Regulation, a polymer is a substance. Importing a polymer does not correspond to the placing on the market of the monomers and any other substance from which the polymer substance originates. The C&L notification provisions for the import of a polymer can therefore only apply to the polymer substance itself.
It should be noted that any residual/unreacted monomers present in the composition of the polymer are considered as constituents of the polymer. Thus, as any other constituent, they should be taken into account for classification of the polymer.
A number of substances and mixtures are exempt from the requirements of CLP in accordance with CLP Article 1. Substances occurring in nature, as defined in Article 3(39) of REACH, are not explicitly included in these exemptions. If substances occurring in nature are placed on the market in a form not listed in Article 1(5) of CLP, which are in the finished state and intended for the final user, they should be classified, labelled and packaged in accordance with CLP.
A biocidal product has to comply with the classification, labelling and packaging requirements under the CLP Regulation and until 1 June 2015, Directive 1999/45/EC. This obligation is confirmed by Article 2(3)(e) and (m), and Article 69(1) of the Biocidal Products Regulation (EU) 528/2012 (BPR).
According to the BPR (Article 20(1)), the applicant for an authorisation of a biocidal product will have to provide a draft summary of biocidal product characteristics (SPC), taking into account the properties of the active substance(s) as well as any relevant co-formulant(s). As mandatory information, the SPC includes the hazard and precautionary statements (Article 22(2)(i) of BPR). Once authorisation is granted, the holder of the authorisation must ensure that the authorised product is classified, labelled and packaged in accordance with the approved SPC, as well as with the CLP Regulation and, until 1 June 2015, Directive 1999/45/EC (Article 69(1) of the BPR). In addition, authorised biocidal products are subject to specific label elements to ensure the effective communication of information on risks resulting from their use and risk management measures (Article 69(2)of the BPR).
When an authorisation holder wishes to change the label elements related to classification that are part of the authorisation of a product, i.e. hazard and precautionary statements, or is compelled by the CLP Regulation to do so, the change has to be notified to all the Member States in which the product is authorised or, where relevant, to ECHA (see Article 50(2) of the BPR and Commission Implementing Regulation (EU) No 354/2013 on changes of biocidal products. If the change leads to new hazard or precautionary statements, the authorisation needs to be updated to reflect this new condition.
There is a tool for all your needs:
There are easy questions you can ask yourself to find out what is the most suitable tool to create your C&L notification(s):
If your substance has multiple compositions (e.g. same main constituent(s) but different impurities) and/or different classification and labelling, the only notification tool you can use is IUCLID 5;
If you want to claim the IUPAC name of your substance confidential, then the only notification tool you can use is IUCLID 5;
If you have a lot of substances to notify, and if your substances are identified by CAS or EC number, then the Bulk XML might be the more convenient tool for you;
If you want to agree with a classification and labelling already notified or registered, then the online REACH-IT tool is the advised tool to use;
If you want to notify agreed classification and labelling on behalf of several manufacturers, or importers, use the group submission (submission on behalf of a group of manufacturers or importers).
All the C&L notifications created using IUCLID 5, the Bulk XML or the online REACH-IT tool have to be submitted to ECHA via REACH-IT.
Figure 1: A tool for your need
To be able to submit a classification and labelling notification for different compositions of the same substance, you will have to create a notification with IUCLID 5.
In section 1.2 of your IUCLID substance dataset, you have indeed the possibility to identify multiple compositions of your substance, as well as the different impurities contained in the different compositions.
Then, in section 2.1, you can indicate the different classification and labelling and link them to the different compositions in section 1.2.
Further information can be found in Data Submission Manual Part 12 - How to prepare and submit a C&L notification using IUCLID at
Details on how to create a notification for mutiple composition are provided in chapter 5.4 of that manual.
You are only able to edit the “Hazard category” or “Hazard statement” if you select the option “Blank” in the “Reason for no classification”. For each hazard class or differentiation either the two fields “Hazard category” or “Hazard statement” are selected or the field “Reason for no classification” must be specified.
IUCLID 5: If you create your C&L notification using IUCLID5, you can use the TCC tool available on the IUCLID website at:
Check the Business Rule validation on your IUCLID dossier with the IUCLID TCC plug-in before submitting it via REACH-IT. To do so
- Click on Run;
- Select Add reference button;
- From Select query result type, select “Dossier” and in the substance chemical name field type the wildcard character (*). Search, select the dossier and assign. Click Next.
If you receive an error message, modify your substance dataset according to the information provided in that error message and create a new dossier. Check this new dossier again with the TCC plug-in.
Online submission: REACH-IT already contains parameters that verify your C&L notifications when you enter your data using the online tool module.
Bulk XML tool: When the bulk C&L notification is created, the macros inside the file will allow you to confirm if the format of your file is compliant in terms of file format and Business Rules. If some mandatory information is missing, the cell in which the data should have been entered is marked in red, and you will not be able to create a xml file using the “Validate data and create XML” button.
Some Business Rules which are related to the submission of the C&L notification, i.e. whether your submission is an initial submission or an update, can only be checked when you actually submit your C&L notification in REACH-IT.
If you have already submitted one or several C&L notifications on behalf of a group of manufacturers/importers, in order to update the composition of the group, you just need to add the new member(s) into your already created group of manufacturers/importers (MI) associated to your C&L notification(s). You can proceed as follows:
In REACH-IT: Go to <Classification and Labelling> - <Manage the Group(s) of Manufacturer(s)/Importer(s)> ;
Select the group you want to modify;
-Click on the ‘View/update group’ button;
-Update your group composition.
While doing that, all the notifications and submission reports associated to this group of manufacturers and importers will be updated with the new group composition.
Thanks to this group management in REACH-IT, it is not necessary to submit an update of the notification every time there is a new member in the group that has submitted this notification.
Note that all the changes in the group definition will be kept and tracked in the REACH-IT database, which means that ECHA and the enforcement authorities will know when a company has joined a group.
LE submits one or several notifications on behalf of a group composed of LE A and LE B. If he updates the group definition in REACH-IT by adding LE X to the group, then automatically LE X will be considered as having submitted the notification too. LE, LE A, LE B and LE X will be considered as notifiers.
The members of a group of manufacturers and importers will not receive a submission report. They will have to contact the original notifier to receive the reference number (or a copy of the submission report). The company submitting the notification will be responsible for informing the group members after successful (or unsuccessful) notification to ECHA and for sharing the submission report received with the members.
Only the company who has submitted the C&L notification file will be able to update the C&L notification. This means that a member of a group is considered as "co-notifier" of a C&L notification, but cannot update a notification.
The situation can be illustrated by the following example:
-In December 2010: you have submitted, on behalf of a group composed of M1 + M2 + M3, a bulk file for the substances S1 (CL1) + S2.
- Now: M1 and M2 want to update S1 with CL2, but not M3 who wants to keep the original C&L (CL1).
There might be different ways to handle this situation depending on the type of agreement that you have made with M1, M2 and M3 outside REACH-IT when you have decided to agree on the C&L of S1 and S2 and submit them as a group of M/I.
Depending on the exact type of agreement between the different members of the group, the following technical solutions are possible:
Technical solution 1:
In the case you, M1, M2, and M3 do agree with both C&L for S1 (the old CL1 and the updated one CL2) for example if the C&L differs because of impurity/additive/form.
Then the C&L notification for S1 can be updated to include a different composition and a different classification and labelling for the same substance.
IUCLID5 is the only tool that allows you to indicate more than one C&L and more than one composition for the same substance. In order to include another composition to your substance, please refer to the Data Submission Manual 12: How to Prepare and Submit a Classification and Labelling Notification using IUCLID available at http://echa.europa.eu/web/guest/support/dossier-submission-tools/reach-it/notification-to-the-cl-inventory, specially chapters 5.4, 5.7.1 and chapter 8.
When submitting this updated C&L notification for S1, you should indicate in REACH-IT that the submission is still on behalf of the same group M1+M2+M3.
While doing that, the following information will be stored in REACH-IT:
-S1 with CL1 and CL2 – notified by M1+M2+M3
-S2 – notified by M1+M2+M3
Technical solution 2:
In the case you, M1 and M2 agree with the new C&L for S1, but not M3.
We advise you to create a new group in REACH-IT (with M1+M2 only). Submit an update of S1 with CL1 on behalf of the new group (M1+M2). This update can be made using the bulk tool or IUCLID or the online tool in REACH-IT.
M3 can then submit his own C&L (CL2) for S1 (with his own REACH-IT account). M3 will then have his own submission report for S1 that he can present to the enforcement authorities if needed.
While doing that, the following information will be stored in REACH-IT:
-S1 with CL1 – notified by M1+M2
-S1 with CL2 – notified by M3
-S2 – notified by M1+M2+M3
The online tool cannot be used if:
- Your substance has multiple compositions or multiple classification and labellings;
- You want to claim confidentiality on the IUPAC name.
If you are in such a case, IUCLID shall be used to create your C&L notification.on.
If you use the Online REACH-IT tool, it will be displayed at the bottom of your webpage in the C&L tab of the REACH-IT online C&L notification module. The "I agree" option will be displayed on your screen once you have entered relevant information regarding the substance identity and optical information of the C&L notification created via REACH-IT (<Classification and Labelling> - <Notify a C&L online>). The system will automatically display a substance already included in the C&L inventory that matches your substance, if applicable, and it will give you the possibility to select the "I agree" option. Within the C&L inventory, two groups of substances should be differentiated:
- Substances with an already harmonised C&L in Annex VI of CLP. The harmonized C&L is legally binding;
- Substances that have already been registered under REACH Regulation including a C&L notification or that have already been notified under CLP Regulation. In this case you can select between one of the classification and labelling notifications provided or propose a different C&L.
However, you, as a notifier, should know that the responsibility to verify that a valid classification and labelling of a substance is provided remains with the notifier. REACH-IT only provides you the means to minimise the administrative work and agree with previous entries.
If your substance has not been previously harmonised, registered or notified, the "I agree" option will not be enabled.
When submitting a dossier (created by the Online REACH-IT tool, IUCLID 5, or the XML bulk) a submission number is assigned to each file submitted.
If the submission is successful (i.e., the virus check, the format check, and the Business Rules checks are passed successfully), then each substance notified receives a “Reference number”, which is also called “Notification number” in the case of a C&L notification, or “Registration number” if a registration dossier was submitted. A notification number will have the following format: 02-XXXXXXXXXX-CC-0000.
The submission and reference number are available in your submission report.
If you update your C&L notification, you will receive a new submission number, but the reference number previously assigned will remain the same.
You can check the classification and labelling (according to the CLP criteria) of substances you have already notified or registered by selecting <Classification and Labelling> - <View submitted C&L> in your REACH-IT account. The results can be exported either in .pdf format or .csv format.
You can also retrieve your notification number (reference number of a C&L notification) from the received submission report, or from the reference number history in REACH-IT: <Registration/Notification> - <Reference number history>.
Figure 4: Search for your submission and reference numbers
You have the possibility to search in the internal classification and labeling (C&L) inventory for all the C&L notifications you have submitted as part of:
A bulk file;
A IUCLID notification;
An Online REACH-IT notification; and
A registration dossier (after a successful registration, i.e. after you have received the registration number).
Only the classification and labelling notifications made according to the CLP criteria are searchable, and you can search only for the C&L notification(s) you have submitted.
To do so, use the <View submitted C&L> functionality available in the C&L menu of REACH-IT:
<Classification and Labelling> - <View submitted C&L>.
Figure 5: View your submitted C&L
There are different search options: by reference number (notification or registration number), EC number, CAS number or Name of the group of manufacturers/importers.
The search results can also be exported in .csv format or .pdf file format.
How can I export to an Excel file the C&L notifications that I have submitted to ECHA?
Once you have searched for the C&L notifications that you have submitted to ECHA, you can export the information in .csv format or .pdf format (see previous question for details).
In case that you wish to export the information to an Excel file, please proceed in the following way:
• Click on “Export the results in .csv”. A dialog box will open asking you to open or save the file;
• Select “save” and save the file to your computer in .csv;
• Open a new excel file;
• Import the .csv data in the excel sheet by selecting “Data” from the excel file menu, then select “Import External data” and finally “Import Data (see screenshot below).
• Select the .csv file that you just saved to your computer and follow the import wizard.
There may be different reasons to that:
- There is a time delay between the moment a C&L notification is assigned a reference number, and the moment the C&L is stored in the internal C&L inventory. Please try again later;
- You are a member of a group, but you are not the one who has submitted the C&L notification on behalf of the group. So, you cannot see the C&L; only the company who has submitted the file can see it. The same applies to joint submission members;
- The C&L information cannot be transferred automatically to the C&L inventory because you have specified more than one composition, and more than one classification and labelling, without linking them together in your IUCLID dossier. Your C&L notification is valid if you have received a reference number, nevertheless it will be transferred later to the C&L inventory
All the tools to create a C&L notification are compatible between each other. This means that you will be able to update your notification via Bulk XML tool (this bulk submission can contain different substances than the initial bulk submission), IUCLID 5, or Online REACH-IT tool; whatever the initial submission tool was.
If you want to update the C&L section from a registration dossier, you will have to update your registration dossier (according to Article 22 of the REACH Regulation). Only if you want to update the classification and labelling of your NONS registration dossier below 1 tonne, a C&L notification instead of a registration dossier update is required.
Further information on how to proceed to submit an update can be found in the Practical Guide 7: How to notify substances to the Classification & Labelling Inventory – chapter 3.5 at: http://echa.europa.eu/web/guest/support/dossier-submission-tools/reach-it/notification-to-the-cl-inventory
If you want to update a classification and labelling notification, you should clearly indicate that the notification is an update of a previous successful notification.
If you create your C&L notification update using IUCLID 5:
On top of the usual information to be submitted, do not forget to specify in your IUCLID substance data-set the following information:
• The EC number or EC list numbers of your substance in section 1.1; and
• The reference number of the notification you want to update in section 1.3.
In the dossier header of the IUCLID dossier:
• Select that the dossier is an update;
• Specify the previous submission number; and
• Give an update reason in the dossier header.
For a successful C&L notification update using IUCLID, please consult chapter 8 of the Data Submission Manual 12 - How to prepare and submit a C&L notification using IUCLID? available at: http://echa.europa.eu/web/guest/support/dossier-submission-tools/reach-it/notification-to-the-cl-inventory
If you create your C&L notification update using the Online REACH-IT tool:
In the Online REACH-IT tool, chose the option “Update a C&L notification successfully submitted”, and enter the assigned reference number.
For a successful C&L notification update using the Online REACH-IT tool, please consult chapter 6.2.3 of the Industry User Manual 16 - How to create and submit a C&L notification using the REACH-IT online tool available at:
Figure 2: Update your C&L notification using the online tool
Bulk XML tool
If you want to update your C&L notification(s) using the bulk XML tool, you should also clearly indicate in your file that the notification is an update.
To do so:
• In the tab ”3- Substances”, specify the assigned reference number of the notification you want to update in column D “Reference number”;
• In the tab ”3- Substances“, select a reason for update in the picklist of column E “Reason for update”.
Figure 3: Update your C&L notification using the bulk XML tool
Nevertheless, if you want to update the classification and labelling provided in a registration dossier, you will have to update your registration dossier (according to Article 22 of the REACH Regulation).
Yes, there is. If you have already successfully claimed a registration number for a substance previously notified under Directive 67/548/EEC, you shall update your registration dossier without undue delay, rather than submit a C&L notification. Further information on how to proceed can be found in the Questions and Answers for the registrants of previously notified substances at: http://echa.europa.eu/web/guest/support/dossier-submission-tools/reach-it/nons. Please be referred to chapter – 3.3 How to prepare my IUCLID5 substance dataset in case of NONS update? – Case 2: Other updates.
For substances previously notified below 1t under Directive 67/548/EEC, and for which no tonnage band update has been done and no update under REACH is required, a separate C&L notification has to be made if the substance fulfils the classification criteria as specified in Annex I of the CLP Regulation. This means:
- If the annual volumes of the NONS substance remain below 1 t, you shall do a C&L notification for this substance. As soon as the volume goes increases beyond this threshold; an update of the registration dossier in form of a complete registration dossier is requested;
- If the annual volume is already above 1 t, an update, in form of a spontaneous update of a registration dossier, is requested.
A notifier can update all data of his C&L notification except the submitting legal entity, the EC number or CAS number. A notifier can, among other things, add more information related to the composition of the substances, update the contact details, update the C&L or update the group of manufacturers/importers. In case of a change of the submitting legal entity you should use the Legal Entity Change tool of REACH-IT.
No, if you have already submitted a registration dossier for your substance, you should submit a spontaneous update of your registration dossier if you want to update the classification and labelling of this substance.
If you are a member of a Joint Submission, and you submitted the C&L information of your substance jointly in both the lead registration dossier and your member registration dossier before 30th November 2010, you need to ask the Lead Registrant to submit a lead registration dossier update including the classification and labelling according to the CLP criteria.
The only exception is applicable to substances previously notified under Directive 67/548/EEC where the annual volume does not exceed 1 t. In this case a C&L notification shall be submitted.
Your contact name has been modified correctly if you have validated successfully your C&L notification update. There is no need to update again your contact details. However, the submission report will display only a contact person with the ‘invoice manager’ status.
If you want to modify the contact person in your C&L notification submission report, follow these steps:
- Create a new contact person in the “Contact” tab available at Company >> View (note: REACH-IT may assign this contact in the submission report of other items, i.e., registrations, if no other contact with ‘invoice manager’ status has been previously defined);
- Update your C&L notification and select the previously created contact.
You can inform ECHA that the manufacture/import of a substance by your company has ceased using the available functionality in REACH-IT (Registration/notification >> Cease manufacture):
- Upon selecting the desired notification and following the steps to confirm it, the status of your notification is changed to “inactive”.
- You can at any point activate the notification again by using the “Restart manufacture” functionality.
- Note that this functionality is shared with the cease/restart manufacture for registration dossiers (deactivation based on REACH article 50(2)).
Further information and step by step instructions can be found under section 3.4 “Cease and restart manufacture” in the REACH-IT Industry User Manual Part 6 – Dossier submission available at: http://echa.europa.eu/support/dossier-submission-tools/reach-it/industry-user-manuals
No, unfortunately there is no specific manual, but you are kindly referred to guidance already available at http://echa.europa.eu/web/guest/support/dossier-submission-tools/reach-it/notification-to-the-cl-inventory. You should observe the following steps to submit successfully your C&L bulk notification:
-Read the Practical guide 7: How to notify substance in the Classification and Labelling Inventory (refer to the website mentioned above);
-Read the Introductory Guidance on the CLP Regulation or the Guidance on the Application of the CLP criteria for specific questions related to the C&L applicable to your substance;
-Download the Bulk XML tool available in the previously mentioned website and extract the contents of the CLnotification.zip file to any folder in your computer;
-Remember to enable macros as described in the release_notes.txt in the CLnotification.zip file;
-Read carefully the instructions in the “About” tab of your downloaded CL notification file;
-Check the C&L notification examples available in your downloaded CLnotification zip file;
- If you need further explanation on the meaning of a specific field, place your mouse over commented fields (with a red triangle on the right-hand corner);
- Save your data using the “Validate data and create XML” button rather than “Save as” option. The tool will save your data without any inconsistent format.
When you submit your bulk XML file via REACH-IT, make sure that you select <Classification and Labelling> - <Notify a bulk C&L> and follow the instructions provided in the submission wizard until you confirm your notification submission.
The Bulk XML tool cannot be used if:
-Your substances are not identified by CAS or EC number;
-Your substances have multiple compositions or multiple C&L;
-You want to claim the confidentiality on the IUPAC name;
-You want to set a new M-Factor or Specific Concentration Limit (SCL).
If you are in such a case, IUCLID shall be used to create your C&L notification
Yes, you can. If a specific concentration limit or M-Factor(s) is already defined in Annex VI to CLP, you must specify it in accordance with the Annex VI entry. Where Annex VI does not provide for a binding value, you may still specify your own specific concentration limit or M-Factor(s) upon the strict conditions of Article 10 to CLP. In this case you shall provide a scientific justification (cf. Article 40(1)(e)). A document cannot be attached in a xml bulk file; therefore the only way to specify a Specific Concentration Limit or M-Factor(s) and to attach the requested scientific justification is to submit a C&L notification using IUCLID or the Online REACH-IT tool.
The tab “Substance” and "Classifications" of the Bulk XML tool is password protected to remind users that the classification of your substances should follow a specific format. Please follow these steps to avoid the use of the password:
-Make sure that your macros are enabled when you open the tool. If you cannot have your macros enabled, once you open your Excel sheet select Tools >> Macro >> Security and select Medium or low. If you change your macro security, close and reopen the Bulk XML tool;
-If you need to enter data into a password protected area, the Bulk XML tool should not be used to create your notification (i.e., more than one composition or more than one classification for a specific substance);
-If you are going to copy and paste data to your Bulk XML tool, we strongly recommend that you use the tabs named after "Personal sheet 1", "Personal sheet 2" to check whether your data format is compliant with Excel;
-When you save your file, do not use the “Save as” option, but rather the “Validate data and create XML” button so you can submit your file to ECHA via REACH-IT. However, if you want to include more substances at a later stage, we recommend that you also save your file in xls format.
Enter the “index number” of the classification already harmonised in Annex VI to CLP under the field “Classification name” within the tab “2-classifications” of your Bulk XML tool. The Annex VI on the Regulation (EC) No 1272/2008 on Classification, Labelling and Packaging of Dangerous Substances can be found at http://ecb.jrc.ec.europa.eu/classification-labelling/clp/.
Once you have filled in the classification name, the C&L information will be automatically populated in the tab “2-classifications” of your Bulk XML tool.
Check the classification and labelling displayed.
Then in the tab “3-Substances”, enter the substance identity of your substance, and select the index number to this substance in the “classification selection” column.
Figure 6: Harmonised C&L in the bulk XML tool
Your XML files might have been created with the Bulk XML tool version 1.0, 1.1 or 1.2.
Those versions of the xml file are not accepted anymore by REACH-IT. We would therefore recommend you to download the new version of the bulk XML tool (version 2.0) which is now available from the ECHA website.
All information previously entered in the former version of the Bulk XML tool are not lost, they cannot only be copied / pasted to the new bulk XML Tool version 2.0; but also imported using the import XML button located on the “about” page.
We therefore advise you to download the new Bulk XML tool:
-Download the complete zip file from:
-Perform the 4-steps procedure explained in the next question (question 25) in order to check your different files that have not been accepted by REACH-IT at the XML validation step
Step 1: download the new version of the Bulk XML tool:
1.1- Download the zip file containing the “C&L Bulk XML creator tool for Excel 2003 and 2007” from the following webpage: http://echa.europa.eu/clp/inventory_notification/tools_download_en.asp .
1.2- Extract all the files contained in the zip. All files shall be extracted in the same folder on your computer.
Step 2: open the Bulk XML tool and enable the macros:
Enable macros before creating a C&L notification to ensure that the application works as designed. Follow these steps to confirm the availability of macros in your program:
2.1- Open the Bulk XML tool: open the file CLNotification2.0.xls;
2.2- You should confirm that your macros are enabled. Follow these steps to confirm the macro security level in your computer:
a. Select the Tools >> Options from your menu bar;
b. Select security and click on macro security;
c. Set the security level to medium or low. If you already have it set to medium or low, go to step 3;
d. Close your CLNotification2.0.xlsb and open it again;
e. Click on the button “Enable macros” (only when security level = medium).
Step 3: check former XML files not accepted:
3.1- In the tab <About>, click on <Import data from XML>
3.2- Select the XML file that you want to check (the one created with the old Bulk XML tool, and that failed the XML validation in REACH-IT), and click on <open>
3.3- After successful import of the file in the Bulk XML tool v2.0, the following message is displayed:
3.4- Click on <OK>
3.5- Go to the tab <1- Contacts> and check it
3.6- Go to the tab <2- Classifications> and check it
3.7- Go to the tab <3- Substances> and check it
3.8- Go to the tab <4- Generate XML> and click on <Validate data and create XML>
3.9- In case of remaining mistakes you will get directed to the error page.
3.10- Correct the remaining mistakes and perform again step 3.8.
Step 4: Import the generated XML file in REACH-IT.
The C&L notification submission report will indicate those substances of your bulk notification that have been successfully submitted. When the notification for some substances fails, it is recommended to exclude the successfully submitted notifications before you submit again your bulk C&L notification.
You can check in the submission report of the bulk submission which notifications have failed and the reason of the failure.
You can also use the <View submitted C&L> module to confirm successful C&L notifications. Select <Classification and Labelling> - < View submitted C&L > and search for your substance using one of the search criteria. If your substance does not appear in the <View notified C&L> table, then it means that the notification has not been successful.