Use of an alternative chemical name
ECHA, C&L Inventory
If the European Chemicals Agency ECHA has approved the use of an alternative chemical name in accordance with Article 24 of the EU CLP Regulation, the use of the name shall be deemed to have been approved in Switzerland from the time at which the Notification Authority has taken note of the following documents and data:
a. Decision of the European Chemicals Agency;
b. Information on substance identity in accordance with Article 49 letter c numbers 1-3.
If, when using the chemical name according to Article 18 paragraph 2 letter b of the EU CLP Regulation, the name and identification number are used as in the Classification and Labeling Inventory according to Article 42 of the EU CLP Regulation, the substance identity according to Annex VI sections 2.1-2.3 of the EU REACH Regulation must be submitted at the request of the Notification Authority.
New substances
During the first six years after the registration, declaration or notification of a new substance, there is no need to deposit a request to use an alternative chemical name. After that period, the chemical name pursuant to art. 18 (2) CLP must be used, or a request to use an alternative chemical name must be submitted.
Request to use an alternative chemical name
Manufacturers of preparations may use an alternative chemical name for a substance (art. 14 ChemO):
a.if they demonstrate that disclosing the name of the substance on the label or in the safety data sheet would put the confidential nature of their business, in particular their intellectual property rights, at risk; and
b.if the substance meets the criteria specified in Section 1.4 of Annex I to the CLP Regulation.
The alternative chemical name shall be a name that identifies the most important functional groups or serves as an alternative designation.
Manufacturers wishing to use an alternative chemical name must make a request* (art. 15 ChemV, fee: 400 CHF) in writing to the Notification Authority.
The use of an alternative chemical name may be requested for a preparation:
a.in a specific composition;
b.with a specific trade name or a specific designation; and
c.reserved for certain uses.
Authorisation to use an alternative chemical name is granted to the manufacturer and is non-transferable.
*Submit IUCLID export files (but not the write-protected dossier files) to the notification authority for chemicals:
1. General Information
2. Classification & Labelling
3. Manufacture, use and exposure (3.1 technological process / 3.5 life cycle description)
4. Physical and chemical properties / 4.1 physical state
14. Information requirements / 14.2 alternative name request (trade names and safety data sheets of the mixture)
