What should the notification include?

Each notification should include the:

  • Name and contact details of the notifier;
  • Identity of the substance, including the name and other identifiers, information related to molecular and structural formula, composition, nature and amount of additives;
  • Classification of the substance according to the CLP criteria;
  • Reason for "no classification" if the substance is classified in some but not all hazard classes or differentiations indicating whether this is due to
    • a lack of data,
    • inconclusive data, or
    • data which is conclusive for non-classification;
  • Specific concentration limits or M-factors, where relevant, including a justification for setting them; and
  • Label elements, including hazard pictograms, signal words, hazard statements and any supplemental hazard statements.


Confidentiality of IUPAC names

Companies may, under certain conditions, keep the IUPAC name of a substance confidential when notifying it to the C&L Inventory. The IUPAC name can be considered confidential and therefore not published in the C&L inventory for:

  • non-phase-in substances;
  • substances only used as one or more of the following:
    • intermediates;
    • in scientific research and development; or
    • in product and process-orientated research and development.

To keep the IUPAC name confidential, companies need to provide in their IUCLID dossier:

  1. A justification including a clear indication of whether the substance concerned is a non-phase-in substance, a substance used as a chemical intermediate, in scientific research and development or in product and process-orientated research and development.
  2. An alternative name for dissemination by ECHA.

Only IUCLID 5 can be used to make such confidentiality flags. How to do this is explained in Data Submission Manual Part 12.

There is no fee for the confidentiality flags in the C&L notification.

An alternative name provided in a C&L notification for dissemination cannot be used automatically for other purposes. An appropriate request is needed to use an alternative name for a substance in a mixture in a safety data sheet or on a label.

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