Regulatory risk management

Together, the REACH and CLP processes – registration, evaluation, authorisation, restriction and classification – aim to identify and regulate substances that have the greatest potential for adverse impacts on human health and the environment.

 

Be aware of regulatory risk management actions for your substance
  • Inform yourself regularly about the regulatory status of your substance, as it may be proposed to be restricted, authorised, or undergo harmonised classification.
  • Consult the public activities coordination tool (PACT) where you can get an overview of substance specific activities that authorities are working on under REACH and CLP regulation. 

 

Make sure that your information on classification and labelling is correct and up to date
  • Always include information on classification and labelling in your registration, regardless of the tonnage band.
  • To classify and label your substance according to CLP Regulation, evaluate the intrinsic hazards of the substance.
  • Check carefully that the harmonised classification reported for your substance is in line with latest update of Annex VI to CLP. Keep in mind that it may fall under a group entry.

 

Classify multi-constituent and UVCB substances correctly
  • As a general rule, base the classification of your substance containing impurities, additives or multiple constituents (a multi-constituent or UVCB substance) on available relevant information on the substance.
  • When you classify for carcinogenic, mutagenic, reprotoxic (CMR) properties or evaluate the bioaccumulation and degradation properties within the hazardous to aquatic environment hazard class, normally base the classification of the substance also on information on the known individual constituents.  
  • If the data on the multi-constituent or UVCB substance show more severe effects than the data for the single constituents (this may happen for classification for CMR or relevant effects on the bioaccumulation or degradation properties), you should use this more severe data for classification.
  • For non-CMR hazard classes, use data from the constituents for classification in accordance with the mixture rules if data on the substance is not available.
  • Do not test a multi-constituent substance for classification purposes if there is data on the constituents.

 

Update your C&L notification
  • 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 to update your notifications.

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