CLI is the Classification and Labelling Inventory, which is held on the European Chemicals Agency website.
This is a reporting platform for all substances either manufactured by reaction in the EU, or imported into the EU. Substances can be products in their own right, or be contained within mixtures or formulations.
Substances must be notified to CLI as follows:
- Hazardous substances, as classified under CLP or identified as Substances of Very High Concern, SVHCs. These must be notified in any quantity, even in milligrams. There is no minimum level below which notification is not required.
- Non-hazardous substances, or not classified under CLP. Notification is required where the quantity made or imported is > 1 tonne per annum, (i.e. the substance is made or imported in REACH-registration quantities).
There are also notification requirements for articles where:
- > 1 tonne per annum is made or imported in articles where a substance is intended to be released or could be released under foreseeable circumstances (regardless of whether the substance is non-hazardous or hazardous).
- or where articles contain a substance of very high concern (SVHC) at > 0.1% w/w, and > 1 tonne per annum of the SVHC is made or imported.
The manufacturer or importer of a substance or article within CLI scope needs to notify all relevant information the CLI within one month of first manufacture or import.
You will need to have signed up to the REACH-IT system to carry out a CLI notification, and this requires your company information and contact details to be inputted.
Information required to be submitted includes:
- Substance identity information, chemical name, CAS or EINECs number.
- Approximate quantity made or imported each year.
- Impurity information, particularly any significant impurities which affect the classification of the substance, these are usually > 1% but can be lower for sensitisers.
- CLP classification of the substance.
- Individual CLP classification of any significant impurities which affect the classification of the substance as a whole.
The CLI notification process is fairly straightforward, and you should be able to do it in-house. If you need help getting used to the CLI process, you should check the ECHA Guidance on CLI notification.
Alternatively, if you have a particular CLI problem which you can’t solve yourself, contact Janet on 01422 24 22 22, or email Janet.