EU C&L Notification: Classification and Labelling of Substances for CLP Compliance

What is the EU C&L Notification?

According to Article 40 of the EU CLP Regulation (EC) No 1272/2008, manufacturers and importers who place a hazardous substance on the EU market must notify the European Chemicals Agency (ECHA) about its classification and labeling. This requirement applies to substances sold on their own or as part of a hazardous mixture. This notification process is referred to as the C&L (Classification and Labelling) Notification.

When is a C&L Notification Required?

C&L notification is required in the following cases:

1. Substances Required to be Registered under REACH

If a substance is manufactured or imported in the EU at ≥ 1 tonne per year and is subject to REACH registration, a C&L notification is required unless the substance has already been registered and the registration dossier includes a valid CLP-compliant classification.

This also applies to substances that are intentionally released from articles requiring registration under REACH.

2. Hazardous Substances Placed on the Market

Any hazardous substance introduced into the EU market must be notified—regardless of the quantity. This requirement applies to substances that:

• Are classified as hazardous under the CLP Regulation
• Are exempt from REACH registration (e.g., polymers), but still meet the criteria for GHS hazard classification

When Is a C&L Notification Not Required?

• If the substance is not classified as hazardous under CLP, and
• If it is not subject to REACH registration, with no hazardous classification appling.

How Are Mixtures Treated?

Mixtures cannot be notified as a single entity. Instead, each individual hazardous component within the mixture must be individually notified if:

• Its concentration exceeds the relevant classification threshold, and
• It contributes to the overall hazardous classification of the mixture

This applies regardless of the amount of tonnage involved.

Who Is Required to Submit the Notification?

The obligation lies with:

• EU manufacturers
• EU importers of hazardous substances or mixtures containing hazardous components that exceed classification thresholds.

Non-EU companies cannot submit C&L notifications on their own.

There is no designated “Only Representative (OR)” role for C&L notifications. However, to protect confidential business information (CBI), non-EU companies have the following options:

• Appoint one EU importer to submit a group notification on behalf of multiple companies
• Entrust a third party to provide technical assistance with the notification, however, the legal responsibility will still lie with the EU importer or manufacturer.

Notification Deadline

C&L notifications must be submitted within one month of a substance being first placed on the EU market.

How to Submit a Notification to the C&L Inventory?

1. Identify the Notifying Party
2. Gather Required Information
   • Substance details: CAS number, purity, composition, and concentrations
   • EU importer information
3. Determine the Classification
4. Submit C&L Notification Online
5. Download Confirmation Report
6. Keep the Information Updated
   You must update the C&L notification if:
   • The classification changes
   • The substance composition or concentration changes
   • The EU importer details change
   • The Contact person changes
   • Upon request by the authorities

Final Thoughts

The C&L notification is an essential compliance requirement under the EU CLP Regulation. It promotes transparency and safety in the handling and labeling of hazardous substances. Timely and accurate reporting not only helps avoid penalties but also fosters trust within the supply chain and supports responsible product stewardship in the European market.

If you require assistance with C&L notification or broader CLP compliance, REACH24H Consulting Group is here to help. Our team offers tailored support to ensure your business meets all regulatory requirements efficiently and confidently.