How to submit and update your C&L notification
You can only submit your notification electronically through the REACH-IT portal on the ECHA website. To do so, you must first sign-up in REACH-IT and create an account.
You may already have an account, have made one or several notifications and you now want to submit an update. Under Article 41 of CLP, notifiers and registrants must make every effort to come to an agreed entry for the same substance, and therefore it is normal for updates to be made to notifications.
To prepare and submit a new notification or a notification update, you should follow these steps:
- Create your account in REACH-IT
If you already have an account, it is not necessary to create a new account for the purpose of notification. If you have forgotten your Reach-IT user name and/or password, you can use the "Forgot your user ID or password?" functionality available in the REACH-IT sign-in page or contact ECHA helpdesk.
- Create a notification group (optional)
The notifiers may also form a group of manufacturers and/or importers and notify their agreed classification and labelling to the Classification and Labelling Inventory. This step is not compulsory. The group of manufacturers and/or importers can be created either directly in REACH-IT or using an offline tool (Group creator).
- Prepare your C&L notification/notification update
You can use either IUCLID 5, Bulk xml or the online notification tool. If you have submitted your notification as part of a registration dossier, you have to submit a registration update (REACH Article 22) to update your notification.
To obtain more information on the tools available, and to check which one is most suitable for you, please click on the links below.
IUCLID 5You can specify all the requested information in IUCLID 5, and create a C&L notification dossier in IUCLID
Bulk XMLYou can create a bulk XML file containing more than one C&L notification.
- IUCLID 5 allows you to include more than one composition for the same substance (e.g. due to different impurity profiles) and link each composition to a specific classification and labelling. Each notifier can only submit one notification per substance and this is the only tool where you can submit several compositions for one substance.
- Previous users of IUCLID 5 may find this practical.
- Also practical for those intending to submit a registration under REACH for the 2018 registration deadline.
The bulk XML file can be created either using the Excel tool provided by ECHA or by using the XML schema (this option may be preferred by users with an IT background).
Online toolYou can manually enter the required data in REACH-IT.
- The bulk XML file allows you to submit notification information for several or a large number of substances defined by their EC or CAS numbers in a single file.
- XML bulk submission can only be used when each substance is identified either by the CAS or EC number and identified by one composition only. In addition, no M-factor or Specific Concentration Limit can be set, if it is not already specified in Annex VI to the CLP Regulation for the substance to be notified.
- Recommended for groups of manufacturers or importers with several substances.
You can consult the short guides on updating your C&L notification for a step-by-step instruction.Note: If your CLP obligations were covered by group notifications, only the importer/manufacturer who submitted it on your behalf will be able to update the notifications. Therefore, you'll have to contact the importer/manufacturer if you need to update the notified classification.
- If you only need to notify a few substances and you are not currently using IUCLID 5, an online notification through REACH-IT could be your preferred option.
- This option could be practical for you if you are an SME, if it concerns a small number of substances and individual legal entities.
- In the online tool, you can agree with a C&L already notified or registered by another company.
- Short guide - update your bulk notification
- Short guide - update your IUCLID notification
- Short guide- update your online notification
- Submit your C&L notification/notification update
- Having prepared your C&L notification IUCLID file or bulk XML file, you can now submit it to ECHA using REACH-IT.
- If you used IUCLID 5, you can check your C&L notification before submitting it to ECHA by using the validation assistant that checks your C&L notification (Business Rules check). The IUCLID 5 website is the access point to download the IUCLID 5 plugin.
- If you used the online notification tool in REACH-IT, you will be guided through dedicated pages to submit your C&L notification.
The content of the public C&L Inventory is then updated on a regular basis. All new notifications and updates to existing ones will be included in the following data refresh.
Important information when updating a notification
For a successful update submission, your C&L notification must be clearly identified as an update of a previous successful notification and contain the following compulsory information:
- The reference number of the C&L notification you want to update: the reference number has the following format 02-XXXXXXXXXX-CCXXXX
- The EC or list number assigned to your substance
- The previous submission number (relevant for notifications submitted in IUCLID only)
- A reason for update. (e.g. a change in classification and labelling to comply with Article 41).
Specific requirements for the different tools
The update of a C&L notification requires:
- In IUCLID: to specify the assigned reference number (notification number) in section 1.3. In the dossier header, you must also specify the previous submission number, tick the "update" box and specify the "update reason".
- In the online tool: to choose the option "Update a completed submission", and enter the previously assigned reference number.
- In the xml bulk submission tool: to specify for the substances updated that the notification is an update and the previously assigned reference number.
Further guidance and information
- Industry User Manual part 6: Dossier submission [PDF] [EN]
- Data Submission Manual part 12: How to prepare and submit a C&L notification using IUCLID [PDF] [EN]
- Industry User Manual part 15: Manage your group of Manufacturers or Importers [PDF] [EN]
- Industry User Manual - Part 16: How to create and submit a C&L notification using the REACH-IT online tool [PDF] [EN]
- Practical guide 7: How to Notify Substances to the Classification & Labelling Inventory [PDF]
- A fact sheet on the public inventory [PDF][EN]
- How to avoid blocking your REACH-IT account [PDF] [EN]
- Overview of the classification and labelling notification duties under the CLP Regulation