How to submit and update your C&L notification
How to submit and update your C&L notification
You can submit your notification electronically either through the REACH-IT portal on the ECHA website, or using ECHA's system-to-system submission service. Regardless of the submission method, you must first sign-up in REACH-IT and create an account.
You may already have an account, have made one or several notifications and you now want to submit an update. 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 for updates to be made to notifications.
To prepare and submit a new notification or a notification update, you should follow these steps:
- Create your account in REACH-IT
If you already have an account, it is not necessary to create a new account for the purpose of notification. If you have forgotten your Reach-IT user name and/or password, you can use the ECHA Accounts contact form to request support.
- Create a notification group (optional)
The notifiers may also form a group of manufacturers and/or importers and notify their agreed classification and labelling to the Classification and Labelling Inventory. This step is not compulsory. The group of manufacturers and/or importers can be created in REACH-IT.
- Prepare your C&L notification/notification update
You can use either IUCLID or the online dossier. If you have submitted your notification as part of a registration dossier, you have to submit a registration update (REACH Article 22) to update your notification.
To obtain more information on the tools available, and to check which one is most suitable for you, please click on the links below.
IUCLIDYou can specify all the requested information in your IUCLID dataset and create a C&L notification dossier.
Online dossierYou can manually enter the required data in REACH-IT.
- IUCLID allows you to include more than one composition for the same substance (e.g. due to different impurity profiles) and link each composition to a specific classification and labelling. Each notifier can only submit one notification per substance and this is the only tool where you can submit several compositions for one substance.
- Previous users of IUCLID may find this practical.
- Also practical for those intending to submit a registration under REACH for the 2018 registration deadline.
System-to-system submission service
- If you only need to notify a few substances and you are not currently using IUCLID, an online notification through REACH-IT could be your preferred option.
- This option could be practical for you if you are an SME, if it concerns a small number of substances and individual legal entities.
- In the online tool, you can agree with a C&L already notified or registered by another company.
The System to System (S2S) submission service is available for those that want to use their own IT systems to prepare and submit C&L notifications.
Note that to submit a S2S submission to REACH-IT you must login to REACH-IT and accept the terms and conditions of use and service of REACH-IT.
Note: If your CLP obligations were covered by group notifications, only the importer/manufacturer who submitted it on your behalf will be able to update the notifications. Therefore, you'll have to contact the importer/manufacturer if you need to update the notified classification.
- ECHA has made the C&L notification format and data model available.
- The format is made available as a set of XML schema definition files (XSDs).
- Notifications can be made in bulk and will be available in REACH-IT and C&L inventory.
- Submit your C&L notification/notification update
- Having prepared your C&L notification IUCLID file, you can now submit it to ECHA using REACH-IT. You can check your dossier before submitting it to ECHA by using the Validation Assistant (Business Rules check). The IUCLID website is the access point to download the IUCLID plugin.
- If you used the online dossier in REACH-IT, you will be guided by the help texts in the application to submit your C&L notification.
- If you want to submit your C&L notification and/or an update via the system-to-system services please refer to the relevant section above.
The content of the public C&L Inventory is then updated on a regular basis. All new notifications and updates to existing ones will be included in the following data refresh.
Important information when updating a notification
For a successful update submission, your C&L notification must be clearly identified as an update of a previous successful notification and contain the following compulsory information:
- The reference number of the C&L notification you want to update: the reference number has the following format 02-XXXXXXXXXX-CCXXXX
- The EC or list number assigned to your substance
- The previous submission number (relevant for notifications submitted in IUCLID only)
- A reason for update. (e.g. a change in classification and labelling to comply with Article 41).
Specific requirements for the different tools
The update of a C&L notification requires:
- In IUCLID: to specify the assigned reference number (notification number) in section 1.3. In the dossier header, you must also specify the previous submission number, tick the "update" box and specify the "update reason".