Product Identifiers

Substances and mixtures have different product identifiers for the CLP label.  Some component substances in mixtures may be required to be named on the label.  These and other component substances may require full identification on the Safety Data Sheet (SDS).

Product identifiers for substances on labels

Substances sold alone (or in dilution) are required to be identified by:

1. their chemical name, or a recognised common name; and
2. an identification number, which has to be either:

• the Index Number (the number used to identify Substances which hold a Harmonised Classification),
• the EC number (a European identification number),
• or the CAS number.

The Index Number, although allowed legally, is not used as often as CAS and EC numbers, which are more commonly used.  A problem with using the Index Number is that it can sometimes cover multiple related substances, so may not always be usable as a number identifier on the label and SDS.  (For more details see https://ttenvironmenta.wpengine.com/clp-knowledgebase/index-numbers/ ).

There is precedence over which identification number should be used on the label and SDS, although, as described above, usually the CAS number and EC number are used but not the Index number.

Precedence of product identification numbers 29-06-2017 (click on image to enlarge it).

To download this flowchart as a pdf:  Precedence of product identification numbers 29-06-2017.

A substance which holds an Authorisation from ECHA is required to print the authorisation number on the label.  (REACH registration numbers are not required to be printed on the label).  However, neither of these numbers are considered to identify the substance formally, as they are administrative numbers.

Product identifiers for substances on SDSs

The substance identification required on the SDS is the same as on the label, that is the chemical name, identification number, and the authorisation number (if Authorised).  The REACH registration number is also required, where a substance has been registered for REACH by the supplier (or one of their suppliers).

Product identifiers for mixtures on labels

Mixtures are required to be identified by:

1. their trade name, and any relevant component substances under “contains” (see below for more details)
2. their UFI, Unique Formulation Identifier, if one is required see: https://ttenvironmenta.wpengine.com/clp-knowledgebase/unique-formulation-identifier/

Product identifiers for mixtures on the SDS

The mixture is required to be identified on the SDS with its trade name and UFI, in Section 1.

Product identifiers for component substances in mixtures – labels

Component substances in mixtures are required to be identified by name only (no identification number) in one of two places on the label:

• immediately below (or after) the trade name, in the format “Contains (name 1, name 2 etc)”
• in the supplementary information, if they are sensitisers covered by EUH208

Note that if a mixture has “contains” component substances, any other EUH208 sensitisers can be added to this list for clarity on the label, so people do not need to read information about components in two places.  For more information see https://ttenvironmenta.wpengine.com/clp-knowledgebase/mixture-components-identified-on-clp-label/ .

In certain circumstances, lower hazard substances can have a different name substituted to protect the confidentiality of a mixture.  , and are not required to report any identification numbers on the SDS.  These substances have either been granted this anonymity by the HSE (prior to 1st June 2015), or ECHA (1st June 2015 onwards).

Product identifiers for substances in mixtures for SDSs

As you might expect, any component substance named on the mixture label is required to be listed in section 3.2 of the SDS.  Other substances may also need to be identified there.

In the SDS, the name and chemical identification number (Index, EC or CAS number) is required to be given, along with the quantity in the mixture.  The REACH-registration number should also be included.  If the substance is Authorised, the authorisation number should be included. The CLP classification is also required. For more information see: https://ttenvironmenta.wpengine.com/clp-knowledgebase/mixture-components-identified-on-sds/ .

Where a component substance has a confidentiality claim and uses a substituted name, this name should also be used on the SDS, and identification numbers are not required (Index, EC or CAS number, or REACH registration number), otherwise it would be possible for the substance to be identified.  However, the CLP classification is still required, to enable anyone using the mixture in another mixture to classify their new mixture correctly.