When to classify a substance for CLP yourself

There are a great many CLP classifications for substances available on the ECHA database, in the Harmonised Classifications list, the REACH dossiers, and the Classification and Labelling (C&L) Inventory.  This means that you may be able to use a published CLP classification, rather than going through the process yourself.

There are also published non-CLP classifications which can be converted into a CLP classification, without needing to classify from data.

However, there are some circumstances when you may need to classify a substance yourself, including:

  • if you are a Lead Registrant, or compiling a REACH dossier for the Lead Registrant, you will need to classify the substance for CLP on the basis of all the published data and any unpublished test data you have been able to find (this classification has to be agreed in the SIEF as part of the REACH process).
  • if your substance has not gone through REACH yet, or is only going to be made or imported at less than 1 tonne per annum, and nobody else has registered it for REACH
  • if you have a novel substance which nobody else is making or importing into the EU
  • if you are importing mixtures containing substances which have not been registered for REACH, or notified to the C&L inventory, you may need to classify the substances for CLP in order to classify the mixture accurately for CLP

Unless you are a Lead Registrant, or import mixtures containing non-registered substances, you may never have to classify a substance for CLP.

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