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.



Leave A Comment

Access to the CLP Knowledgebase is restricted to people who have completed our CLP training course in person or online (coming soon), or other competent professionals. For more information on our next live training course, or to request access to the CLP Knowledgebase, please email us.
Access the CLP Knowledgebase
Sign InSign In