How to notify to the C&L Inventory
Notification to the C&L Inventory is made using the REACH-IT system on the ECHA website.
Notification is free (apart from the time you need to do this), and obtaining a REACH-IT log-in is also free. If you have pre-registered a substance for REACH, you will already have a REACH-IT log-in.
REACH-IT can be accessed from https://reach-it.echa.europa.eu/reach/ . REACH-IT is generally open 24 hours Monday – Friday, but closed over the weekends. It is also closed on Finland’s Bank Holidays, see http://www.officeholidays.com/countries/finland/ for details. REACH-IT can also be closed for maintenance and upgrades. If REACH-IT is not working, the reasons are usually given on the ECHA homepage at https://echa.europa.eu/ , and you should check this before trying to report that REACH-IT has broken down.
As well as your company and contact details, the information required for the CLI notification includes:
- chemical name
- identification numbers (if any available)
- chemical formula
- chemical structure, if available
- quantity made or imported into the EU per annum (can be updated if this changes)
- CLP classification (can also be updated if this changes)
If other people have notified the same substance to the CLI, you can choose to classify your substance in the same way as them.
However, unlike a REACH registration where test data is required to support each hazard classification (or decision that a hazard does not apply to the substance), and where you can see summaries of the test data (or modelling or read-across decisions), under CLI, actual data like this is not published.
In effect, you are taking the CLI notification on trust, unless you can see that the substance has been registered for REACH, and can review how this classification was arrived at.
For non-REACH registered substances, you cannot see the name of the company which has made the classification decision in the first place. One way round this is to agree to a classification from a reputable supplier or competitor where you feel confident relying on their classifications. Another option can be to go with the most popular CLI notification, but you then may find that this is different to a later REACH registration classification.
We have an old paper on CLI Notification which may be of interest, although please note parts of it have been superseded as the notification process within REACH-IT has changed since it was written: CLP Notification direct from REACH-IT v1.2 13-06-2014