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Data Dissemination and Confidentiality

CLP

A. CLP, General

What is the Classification & Labelling Inventory?

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.
What is published in the public Classification and Labelling (C&L) Inventory?

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.


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.


The Public C&L Inventory does not contain contact details of notifiers or registrants. 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 the manual Dissemination and Confidentiality under REACH Regulation). If so, it will not be included in the Public C&L Inventory.


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.

How are C&L notifications for the same substance grouped and what aggregation rules are applied?

The notifications for each substance are grouped together based on numerical identifiers such as EC or CAS numbers, where they exist. The aggregation is done automatically based on both classification and labelling elements.

  • Identical classifications are aggregated and displayed as one entry. The Number of Notifiers behind each aggregated classification is indicated. 
  • Different States/Forms of the substance (e.g. liquid, solid:bulk, solid:particulate/powder, solid:nanoform) are added under Additional Notified Information.
  • Classifications derived from joint submissions to the REACH registration process are marked ‘yes’ in the Joint Entries column.
  • Reasons for no classification are not taken into account during aggregation. They are reflected in the View details section of each classification entry.


 

Why are there differing classifications for the same substance?

One of the objectives of the C&L inventory is to promote uniform classification of substances. 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).

For many substances different classifications have been notified to ECHA. There are several reasons for the range of different classifications:

  • slight differences in seemingly identical notifications (e.g. differences in affected organs or route of exposure);
  • different interpretation of scientific studies or different access to such studies;
  • technical errors made during the notification process (e.g. not assigning all labelling elements correctly)

There may be other legitimate reasons for different classifications for the same substance:

  • different compositions or impurity profiles often lead to different classifications;
  • 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.
Can I use the classification and labelling information published in the public C&L Inventory to choose a ‘correct’ classification?

The C&L Inventory displays notified classifications as they are reported to ECHA without any verification by the Agency. The notifications reflect, therefore, the current 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. We encourage all users to discuss their concerns with their suppliers but there is no single "correct" classification identified and highlighted by ECHA.

The C&L Inventory indicates where a legally binding harmonised classification is included in Annex VI of the CLP Regulation and where the classification of a substance was derived from the joint submissions to the REACH registration process.

Is it possible to delete a C&L notification from the inventory when a company ceases manufacture or import?

Ceasing of manufacture or import does not mean that a substance is no longer present on the market. For this reason, the classification and labelling information of a substance remain available in the C&L inventory even after the manufacture or import has been discontinued.

Why are the precautionary statements not published?
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.
Some aggregated notifications have no classification elements visible while others are labelled "not classified". What is the difference between these?

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 without ticking the “Not Classified” tick-box. 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.

How can I download the whole C&L inventory?

At the moment, it is only possible to download part of the C&L inventory in batches using the advanced search (accessible from the home page). The current search functionalities of the advanced search are based on classification only. Therefore, notified substances which are not classified as hazardous won’t be returned by the current searches.

If you want to download part of the C&L inventory, use the starting digits of the EC numbers to limit the number of entries in a batch. We suggest using the following: 20, 21, 22, 23, 24, 25, 26, 27, 28, 29, 3, 4, 5, 6, 7 ,8, 9.

advanced chemical search

B. CLP, C&L inventory search

How can I search information in the Public C&L Inventory?

A substance can be identified by searching either with the CAS number or the official EC number. For a substance with a harmonised classification and labelling, the Annex VI Index number, or the substance name can be used.

Whilst there is an information filter option present on the C&L Inventory portal page, the Advanced Search function present on the ECHA homepage is a far more powerful and versatile tool for finding relevant information in regard to Classification and Labelling, allowing for selection of specific hazard classes and selection of the information source.

These options can be combined with any of the other search functions of the Advanced Search, including most obviously, the substance identifiers section.

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.

Is it possible to export data from the C&L Inventory?

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

Are there any limitation to the usage of data from the C&L Inventory?

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.

C. CLP, Harmonised classification and Seveso

Is the harmonised list according to DSD criteria (Table 3.2 of Annex VI to CLP) in the Public C&L Inventory?

No, all harmonised DSD classifications have been erased from public view as these are no longer relevant.

How can I verify if the classification and labelling of a substance has been harmonised (CLH) according to GHS?

Substances with a harmonised classification and labelling (CLH) are listed in Annex VI to CLP. You can also find if the classification is harmonized by examining the text below the pictograms in the relevant substance InfoCard. 
 


Alternatively, you can look for your substance in the C&L inventory and open the summary of classification and labelling page. 


 

How do I know if my substance is covered by the Seveso Directive?

You should look for your substance in the C&L inventory and open the summary of classification and labelling page to find if your substance is covered by the Seveso directive.



Please note that ECHA is not an authority for the Seveso Directive and that the Seveso categorisation is provided for information only. The Seveso III Directive (Directive 2012/18/EU repealing Directive 96/82/EC (Seveso II) from 1 June 2015) is the only authentic legal reference and that the information in this inventory does not constitute legal advice. For further information on Seveso, please ask your national authority.