There are two possibilities for drafting a C&L notification that is then submitted via the REACH-IT portal:
- directly online (REACH-IT)
- C&L notification dossier in IUCLID5
The group of manufacturers or importers (MI-group) can be managed in REACH-IT itself.
non-harmonised classifications (FAQ CLP)
It is possible to notify a classification that differs from the already available entries in the inventory for the same substance. Possible grounds for different classifications for the same substance can be
- differing contamination profiles.
- Different interpretations with data analysis
- Different interpretations when using the CLP classification rules
However, Article 41 CLP demands that notifiers and registrants in the EU use their best efforts to reach a mutually agreed entry for the same substance, in so far as there are no grounds (e.g. contamination profile) for differing classifications.
harmonised classifications (FAQ CLP)
If a certain hazard class or differentiation is harmonised by Annex VI CLP, then this classification must be used for the notification for the C&L inventory database. For substances from Annex VI with a minimum classification (marked with an asterisk), the notifier must classify in a more severe hazard category in cases where he has information that shows that this is more appropriate. For non-harmonised hazard classes or differentiations of substances from Annex VI, the EU manufacturer or notifier must undertake his own classification and enter the resulting classification and labelling in accordance with Art. 4 (3) CLP in his notification. In cases where he concludes that the substance need not be classified in one of these hazard classes or differentiations, then in accordance with Art. 40 (1) d CLP, he must provide the grounds for the non-classification.
