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C&L Notification | Missed Notification Deadline?

CLP stands for the Regulation (EC) No 1272/2008 on the Classification, Labeling and Packaging of substances and mixtures. CLP introduces the United Nations globally harmonized system (UN GHS) for classification and labeling of chemicals into Europe. CLP entered into force on 20 Jan 2009.

CLP requires that information on substance identity, classification and labelling (“C&L”) of a substance should be notified to ECHA. This is known as “C&L Notification”. ECHA will include this information in a database, called the Classification and Labelling Inventory.

Note: Polymer shall also be notified if classified. More info about how polymers are regulated in EU and other countries can be found here.

When is C&L notification deadline?

When the substances are placed on the market

C&L notification deadline

Before 1 December 2010

3 January 2011

After 1 December 2010

Within one month from the first time they are placed on the market

 

ECHA has indicated in its FAQs that if you missed C&L notification deadline, you shall notify without any delay to avoid legal penalties. You can avail of our CLP notification service by using our application form.

More info can be found at:

http://echa.europa.eu/clp/info_clp_companies_en.asp

Who shall submit C&L notification?

  • EU manufacturer or importer of a substance that is subject to registration under REACH;
  • EU manufacturer or importer of a substance that is classified as hazardous irrespective of the quantity;
  • EU importer of a mixture which contains the substance that is classified as hazardous and is present above the relevant concentration limit, which results in the classification of the mixture as hazardous according to the CLP Regulation.

 

What is New?

6 May 2012, ECHA finally allows Only Representatives to submit C&L notifications on behalf of importers. More info can be found here.

How to submit C&L notification?

C&L notifications will be submitted electronically via the REACH-IT system. The following information is required for C&L notification:

  • your identity and the identity of substance;
  • the classification of the substance;
  • indication of why if the substance has been classified in some but not all CLP hazard classes;
  • if applicable, specific concentration limits, or M-factors related to the classification as hazardous for the aquatic environment together with a justification for the use; and
  • the labeling elements for the substance, including the supplemental hazard statements referred to in Article 25(1).

 

There is no fee for making C&L notifications. Companies will ultimately have three options for submission of CLP notifications.

  • via IUCLID 5.2 (notification dossier is prepared in IUCLID 5.2 and submitted to ECHA in REACH-IT). The only notification tool for a substance whose classification changes with the composition (for example, constituents and impurities);
  • directly to REACH-IT using an XML form for bulk submissions. Recommended for a legal entity who has several or a large number of substances (identified by CAS or EC) to notify.
  • ONLINE via REACH-IT. Recommended for a Legal Entity who only needs to notify a few substances. The best option for SMEs.

 

After C&L notification is submitted, a submission report with reference number beginning with 02-xxx will be issued. These reports would allow notifiers to show compliance towards Member States Competent Authorities.

How can we assist you in complying with CLP?

We provide end-to-end solutions to CLP compliance. We can help you classify your substances and mixtures according to CLP, notify the classification and labeling of your products to the C&L Inventory, prepare CLP compliant labels and the latest Safety Data Sheets.

Even though there are many guidance documents on how to prepare CLP compliant label, it is much easier and less time-consuming for you to outsource this job to us.

  • Regulatory advice on the implications of CLP and REACH for your company;
  • Re-classification and re-labeling of your substances or mixtures;
  • Preparation of CLP compliant labels;
  • Notification to the Classification & Labeling Inventory (C&L notification);
  • New Safety Data Sheets in accordance with CLP & REACH;

About CIRS

CIRS a leading provider of comprehensive chemical compliance services for companies doing businesses in/with EU and China with a strong focus on chemical compliance.

With a strong presence in EU and China, CIRS has provided cost-effective regulatory support to over 3,000 companies while doing businesses in both the EU and China.

CIRS is the largest REACH only representative in the world. Since 2007, we have:

  • pre-registered over 10,000 substances;
  • acted as only representative for over 2,400 non-EU companies;
  • served clients in more than 25 countries;
  • registered over 145 substances to date;
  • prepared over 1000 REACH SDS and CLP labels to date;
  • submitted over 500 C&L Notifications to date;

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CIRS is a recommended service provider by China Inspection and Quarantine Bureau, the US Mission to the EU and IDA. CIRS is also a member of Helsinki REACH Centre.

Contact

CIRS offers C&L notification service at 150 Euros per substance. Discount is available for multiple substances. CIRS also offer CLP compliance package price (notification+SDS+label) from 300 Euros per substance. For more information about how CLP might affect your business and how to comply with CLP, please contact.

  • Europe Office
    Unit 1 Ardee Business Park, Hale Street, Ardee, Co. Louth, Ireland
    Tel : +353 41 9806 916 | Fax : +353 41 9806 999
    Email: service@cirs-reach.com