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CLP

Request for use of an alternative chemical name

What fees are payable for requests for use of an alternative name?
A manufacturer, importer or downstream user of a substance in a mixture may submit a request to the European Chemicals Agency, hereinafter 'the Agency', to use an alternative chemical name on the label and in the safety data sheet. Such requests under Article 24(1) should be accompanied by a fee. The level of the fees collected by the Agency, as well as the rules for payment are determined by Regulation (EU) No 440/2010 of 21 May 2010 on the fees payable to the European Chemicals Agency, are pursuant to Regulation (EC) No 1272/2008.
When diluting a substance in water, can we consider the result of this dilution as a mixture and, as such, to fulfil the conditions of Article 24 (1) of the CLP Regulation allowing submission of a request to use an alternative chemical name?
According to CLP Article 24(1), a request to use an alternative chemical name on the label and on the safety data sheet refers to a substance in a mixture where the substance meets the criteria set out in Part 1 of Annex I to CLP.
 
When a substance is diluted with water, the water can be separated from the substance without affecting the stability or changing the composition of the latter, see CLP Article 2(7). Consequently, the diluent water must be considered as a substance on its own. When a diluent is mixed with another substance, a mixture in accordance with the definition set out in CLP Article 2(8) is generated.
 
Thus, a substance which is diluted in water and which meets the criteria set out in part 1 of Annex I to CLP is eligible for a request for an alternative chemical name according to CLP Article 24.
What is the purpose of requesting an alternative chemical name for a substance contained in a mixture?
If disclosing the full composition of a mixture on the label or in the safety data sheet would put the confidential nature of your business at risk, you can request permission to use an alternative chemical name for a substance in the mixture, in line with the provisions under Article 24 of the CLP Regulation. You can submit the request to ECHA for substances that fulfil the criteria set out in section 1.4.1 of Annex I to CLP. If ECHA accepts the request for an alternative chemical name, the name will be valid in all EU Member States and the alternative chemical name can be used on the label and in the safety data sheet of the mixture.
How can I request the use of an alternative chemical name for a substance contained in a mixture, in accordance with Article 24 of the CLP Regulation?
A request for the use of an alternative chemical name, according to Article 24 of the CLP Regulation, can be submitted to ECHA by submitting a IUCLID 6 dossier in REACH-IT by using the ‘Alternative chemical name request’ functionality.
How to submit a dossier

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