Voluntary reporting of a preparation in the Chemicals Product Register (RPC)
Voluntary reporting (within the meaning of Art. 48 ff. ChemO, SR 813.11) of chemical preparations not subject to reporting in the Product Register for Chemicals (RPC)
Summary
Sometimes – and often for commercial reasons – manufacturers (within the meaning of Art. 2 para. 1 letter b, ChemO) would like preparations, that are not subject to the obligation to notify, to be reported in the register of products (RPC).
The legislation does not envisage the need for accepting such reporting, but neither does it forbid this option. The authorities have therefore concluded that such reporting – provided it complies with certain rules – can furnish additional information that could prove useful for the purposes of protection as envisaged by chemicals legislation.
Rules relating to voluntary notification on a preparation
Option 1
If the manufacturer possesses the required information, this is the option recommended by the authorities:
The notifier reports the full composition and indicate the classification and labelling of the preparation.
In other words, one follows the same rules that apply to a preparation intended for the general public and subject to the obligation to notify.
Option 2
If the notifier does not have information on the full composition, it has to use under heading composition the ideal substance created for this purpose and named "Preparation that is exempt from the obligation to report" (PAID 770407-96) with concentration state as 100%. The classification and labelling corresponding to the product's properties has also to be indicated:
- Both options work with the latest version of the mass registration interface
- We recommend that the safety data sheet (SDS) should also be submitted