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May 28, 2010

ECHA Summarizes Details and Location of Information Regarding CLP Notification

Bergeson & Campbell, P.C.

In a recent European Chemicals Agency (ECHA) e-News release, dated May 19, 2010, ECHA provides a brief summary and Internet links to several important press releases to assist notifiers. The release provides a brief overview of the duties that are required to be met under notification along with access to documents and web pages that provide assistance on performing Classification, Labelling and Packaging (CLP) notifications in association with the CLP Regulation (1272/2008). This memorandum reviews some of those duties.

Overview of Duties

This section looks at the Who, What, and How of CLP notification that will be used to populate the Classification and Labelling Inventory. It shows the duties that are placed on European Union manufacturers and importers and provides details on what should be included in a notification and how that notification is undertaken. This information can be found online.

The Documents and Web Pages

To assist notifiers in better understanding the process, ECHA has provided guidance to answer the question on “How” to notify. ECHA has two documents available: Data Submission Manual: Part 12 — How to Prepare and Submit a Classification and Labelling Notification using IUCLID; and REACH-IT Industry User Manual: Part 15 — Manage your Group of Manufacturers or Importers. In the case of the latter, a few significant additions are worth noting. The term “Group of Manufacturers or Importers” (Group of MI), whereby joint notifications can be made under CLP, is clarified along with further guidance on how REACH-IT can be used for notifications. Both documents are available online.

Also available is Practical Guide 7: How to notify substances in the Classification and Labelling Inventory, which offers further clarification on how to notify substances in the Classification and Labelling Inventory. In the event that a REACH-IT account has not been previously created, this document provides a process description, namely four steps — creating a REACH-IT account, creation of a notification group, and if required, preparation and submission of the Classification and Labelling notification. This information is available online.

Also available is an Excel Tool that will assist notifiers in generating Classificaion and Labelling notification files in the XML format that can be submitted via REACH-IT. The Excel Tool is available for download online.