When and what to notify to the C&L Inventory

Companies or natural persons are legally obliged to notify any substance they make or import into the EU to the Classification and Labelling (C&L) Inventory within 30 days of first manufacture or import.

Substances can be:

• pure substances (or with impurities)
• contained in mixtures
• contained in articles

Mixtures and articles are not notified to the C&L Inventory.

The good news is that if you hold a REACH registration for a substance which you manufacture or import into the EU, then this is deemed to be notified to the CLI automatically.

The bad news is that if you haven’t got a REACH registration yet, or you are making or importing a substance (either by itself or in a mixture) at less than 1 tonne per annum, you may need to notify it to the C&L Inventory.

And there is no de minimis amount for notification to the C&L Inventory, in theory even a quantity at the milligram scale for a new substance is required to be notified.

Full advice on what to notify is given on the ECHA website at https://echa.europa.eu/regulations/clp/cl-inventory/notification-to-the-cl-inventory , and summarised in the C &L notification flowchart:

Overview of CLP Notification Liability (click on image to enlarge it).

Download flowchart as a pdf here: C&L Inventory Notification Flowchart .

Substances made outside the EU may be notified by the Only Representative as part of the REACH registration process, but any non-REACH registered substance should be notified by the importer.

Reminder: it is the legal liability of the manufacturer or importer to ensure that each substance is checked for C&L notification liability, and notification to the C &L Inventory is made where appropriate.