Q&As
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CLP
Notification-Classification and Labelling Inventory
Is it possible to flag confidentiality of certain information when notifying to the C&L Inventory?
Yes, it is. Manufacturers and importers can flag confidentiality of the IUPAC name when notifying certain substances to the Inventory. The substances for which confidentiality of the IUPAC name is possible are those listed in Articles 119(2)(f) and (g) of REACH, i.e.
- non-phase in substances,
- substances only used as one or more of the following:
- as intermediates,
- in scientific research and development,
- in product and process orientated research and development.
Where confidentiality of the IUPAC name is flagged when a substance is notified to the Inventory, the IUPAC name will not be displayed on the public part of the Inventory on ECHA's website. Where the IUPAC name has already been claimed confidential under a registration of the substance and ECHA has accepted the justification, the confidentiality claim will automatically be valid for the Inventory as well.
How do I flag confidentiality of the IUPAC name for an eligible substance when notifying it to the C&L Inventory?
The confidentiality flag of the IUPAC name should be flagged when creating an online or IUCLID C&L notification.
- set a confidentiality flag for the IUPAC name of the substance by ticking the appropriate box;
- attach a justification, including a clear indication whether the substance ranks among those referred to by REACH Article 119(2)(f) and (g), and
- introduce an alternative name which would be disseminated on the public part of the
Inventory instead of the IUPAC name. To derive an alternative name, he should apply the rules set out in Part B of Annex VI to Directive 1999/45/EC (Dangerous Preparations Directive).
Notifiers are requested to provide all three elements for flagging confidentiality.
Is it necessary to pay a fee for flagging confidentiality?
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.
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